AML/CFT for DNFBPs: Accountants, Lawyers & Company Secretaries — CWC & ENG PLT
CWC & ENG PLT
Request a consultation
Articles & Resources
AMLA 8 min read·23 July 2026

AML/CFT for DNFBPs: Accountants, Lawyers & Company Secretaries

Designated non-financial businesses and professions are reporting institutions too. If you are an accountant, lawyer, company secretary, real-estate agent or dealer in precious metals, AMLA applies to you.

01

Who is a DNFBP

AMLA's obligations do not fall only on banks and insurers. Designated non-financial businesses and professions (DNFBPs) are invoked as reporting institutions under the First Schedule of AMLA and supervised for AML/CFT purposes. In Malaysia this includes:

  • Accountants and audit firms
  • Advocates and solicitors (lawyers)
  • Company secretaries and trust or company service providers
  • Real-estate agents
  • Dealers in precious metals and precious stones
  • Licensed casinos and gaming operators
02

When the obligations bite

For most professions, AML/CFT obligations attach to specific “gatekeeper” activities — the transactions where a professional can, wittingly or not, help move or disguise illicit funds. For accountants and lawyers these typically include:

1

Managing client money or assets

Handling funds, securities or other assets on behalf of a client.

2

Company & arrangement formation

Creating, operating or managing companies, trusts or similar structures.

3

Real-estate & business transactions

Acting in the buying and selling of real estate or business entities.

4

Managing accounts

Managing bank, savings or securities accounts for clients.

03

The same core obligations apply

As reporting institutions, DNFBPs carry the same AML/CFT duties as financial institutions, scaled to their risk:

  • Customer due diligence and beneficial-ownership verification
  • A risk-based approach and an institutional risk assessment
  • Suspicious transaction reporting to BNM
  • Record-keeping sufficient to reconstruct transactions
  • A compliance programme with a designated compliance officer and staff training
Professional privilege is not a blanket shieldLegal professional privilege has limits in the AML/CFT context and does not extend to advice sought to further a crime. Professionals should understand precisely where privilege applies before relying on it to withhold a report.
04

Why DNFBPs are under growing scrutiny

The FATF and Malaysia's own National Risk Assessment recognise DNFBPs as attractive channels for laundering — professionals lend legitimacy and access to structures. Supervisory attention on the sector has intensified, and firms that treat AML/CFT as a box-ticking afterthought are increasingly exposed to enforcement and reputational risk.

05

Where a professional firm should start

  1. 1
    Confirm you are in scope
    Map your services against the gatekeeper activities to confirm which engagements trigger obligations.
  2. 2
    Build a risk assessment
    Assess your clients, geographies, services and channels, and document it.
  3. 3
    Put CDD and screening in place
    Establish onboarding CDD, beneficial-ownership checks and sanctions screening proportionate to risk.
  4. 4
    Appoint a compliance officer and train staff
    Designate responsibility, write your policy, and train everyone who touches client engagements.
  5. 5
    Test it independently
    Have the framework reviewed by an independent party to find gaps before the supervisor does.
FAQ

Frequently asked questions

Yes. When carrying out specified gatekeeper activities — such as managing client money, forming companies or trusts, or acting in real-estate and business transactions — they are reporting institutions under AMLA.
The core obligations are the same — CDD, risk assessment, STR reporting, record-keeping and a compliance programme — applied on a risk-based, proportionate basis.
Not entirely. Privilege has defined limits in the AML/CFT context and does not protect communications made to further a crime. Firms should understand exactly where it applies.
Bank Negara Malaysia acts as the AML/CFT supervisor for reporting institutions including DNFBPs, working with the relevant professional and sectoral bodies.
—

In conclusion

If your firm performs gatekeeper activities, AMLA applies to you as fully as it does to a bank — just scaled to your risk. The firms that get ahead of it now will not be the ones explaining gaps to a supervisor later.

AMLA · AML/CFT Advisory

AML/CFT support for professional firms

We help accountants, secretaries and other DNFBPs build proportionate AML/CFT frameworks — and test them independently.

Request a consultation