Last updated: May 2023

Halogen Capital, a licensed Digital Asset Fund Manager regulated under the Securities Commission Malaysia, is steadfast in its commitment to combat the scourge of money laundering and terrorist financing, both of which are criminal acts that inflict untold harm on society. 

We recognize that most countries have implemented Anti-Money Laundering (AML) and Counter Terrorism Financing (CFT) legislation that imposes stringent obligations on financial service providers to prevent these criminal activities. Halogen Capital remains committed to adhering to the highest standards of regulatory compliance and industry best practices. Our resolve to thwart money laundering and terrorist financing is unwavering, and we have implemented robust systems and controls that meet the exacting standards expected of regulated sectors such as banking.

Our risk-based approach to the assessment and management of money laundering and terrorist financing risks, as well as our Customer Due Diligence (CDD) procedures, are world-class. Our investors are required to provide certain personal details and documents when opening an account with us. We will be performing enhanced due diligence procedures for investors presenting a higher risk, such as those transacting large volumes and Politically Exposed Persons (PEPs).

We have established risk-based systems and procedures for monitoring ongoing customer activity and reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate. We maintain appropriate KYC records for the minimum prescribed periods, provide training on the framework, and raise awareness among all relevant employees.

We are guided by the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 ("AMLATFPUAA"), along with any relevant laws, regulations and guidelines with regards to anti-money laundering and anti-terrorism financing in Malaysia. As such, we have put in place process and procedures to:

  • guard against, detect, and report any incidents of money laundering and financing of terrorism to Bank Negara Malaysia;
  • mitigate and manage actual and/or potential exposure to financial crime and breaches of legislation or regulation;
  • ensure that there are robust procedures and controls in place; and
  • protect the assets and reputation of Halogen Capital. 

These process and procedures include:


We practise a risk-based approach in assessing our potential and existing customers in order to rate and group them according to the risk of money laundering and terrorism financing (ML/TF) associated with them due to or arising from their origins and location of business, their background and profile, their nature of business, and their structure of ownership. This helps us in assessing and mitigating these risks and is crucial in detecting and preventing our group of companies from being used for and/or involved in any ML/TF activities.

Customer Due Diligence (“CDD”) is conducted on all potential and new customers, as well as Enhanced Due Diligence (“EDD”) to customers assessed as higher risk. Periodic reviews for all our existing customers are performed to ensure that a customer’s profile remains updated and relevant.

We will not commence any business relation, or execute any transaction, and may terminate business relationships if a customer fails to comply with our CDD requirements.


Screening for listed names is an integral part of our CDD process and we conduct screening on all our new and existing customers against the following lists:

  • Our internal watchlist in which we maintain a database of blacklisted individuals and corporate entities for detection of suspected persons; and
  • Politically Exposed Persons and entities/individuals who are sanctioned/suspected/convicted of offences.


We have put in place processes and systems designed to monitor customer transactions for the purpose of identifying suspicious activity. We review, from time to time, amongst others:

A comparison of the customer’s transactional activities and their investment objectives and their profile;

Whether the amount of money involved is consistent with the occupation and nature of business of the customer.


Halogen Capital maintains a strict no cash payment and no third-party payment policy, where we only accept payments made for investments from our customer’s personal bank account. We also do not pay our customers in cash, and only directly to our customer’s personal bank account. Halogen Capital reserves the right to seek out additional information/documents as we believe necessary in order to comply with this policy.


All employees and agents are required to report any unusual transactions to the Compliance Officer, and we will notify the authorities as soon as suspicious transactions are identified using a Suspicious Transaction Report (STR) to the Bank Negara Financial Intelligence and Enforcement Department. 


We continuously provide our employees and agents with training to create awareness with regards to their AML/CTF responsibilities with special emphasis on those employees (e.g. front-line employees) who are exposed to higher risks of potential ML/TF. These trainings are conducted on a regular basis, to keep employees and agents informed of any new changes in legislation or guidelines issued by the regulatory bodies.