KUMARA DEVAN SUBRAMANIAM

Position Objective: To provide strategic leadership and oversight in compliance and regulatory matters, ensuring Boardroom Outsource Services Sdn. Bhd. consistently meets statutory, regulatory, and governance requirements while supporting clients with high‑quality, risk‑focused and value‑driven compliance solutions.

Function - Specific Activity

AML/CFT and ABAC

• Ensure the Company’s policies and processes are kept up to date with relevant laws, regulations and guidelines in relation to AML/CFT, Know Your Customer (KYC) and ABAC, including overseeing and implementing appropriate compliance programs.
• Develop or enhance compliance policies, manuals, procedures, systems and control mechanisms in line with regulations and best practices, ensure that the policies are communicated with all employees in the Company.
• Ensure proactive and timely identification, assessment, advice and dissemination of evolving regulatory change/practices throughout the Company across the region (with a focus on Malaysia).
• Maintain appropriate relationships with relevant regulators, authorities and independent auditors and liaise with them on audits, reporting and implementation of corrective measures.
• Oversee the completion and submission of Data & Compliance Reports to BNM.
• Conduct regular Institutional Money Laundering/Terrorism Financing Risk Assessments and Corruption Risk Assessments.
• Conduct internal compliance reviews on the AML/CFT and ABAC compliance program's to identify gaps against regulations and internal policies and recommend or implement corrective measures.
• Establish, enforce and maintain effective processes (including training and development of appropriate supporting tools) to ensure that compliance policies, procedures and standards are effectively implemented across the Company.
• Perform management reporting to the Board, Senior Management and Group Director, Legal & Compliance on compliance risks and issues.
• Provides regulatory advisory on compliance-related matters to business units or member offices.
• Undertake investigations on suspicious transactions/activities escalated to Compliance and submit STRs to BNM where necessary. Provide guidance to stakeholders concerned regarding any follow-up actions and monitor the closure of such actions.
• Review and provide comments on ABAC-related matters in relation to client policies, agreements, contracts, questionnaires etc.
• Prepare training materials and provide trainings to the Board, Senior Management, new and existing employees on the Company’s policies and compliance programs.
• Provide advisory to business units in relation to the Companies Commission of Malaysia’s (CCM) Guideline for The Reporting Framework for Beneficial Ownership of Legal Persons
• Provide guidance to the business units on BNM and the CCM’s respective Beneficial Ownership requirements.
• Assist business units with matters relating to the disclosure of the Company’s shareholding/Beneficial Ownership information to regulators/external parties.
• Support Group Risk on all Risk Management matters including managing Incident Reporting and Risk Register on the firm’s Risk Management platform.
• Support Group Risk on Group Insurance, Personal Protection and Business Continuity Management.

Position Objective: To manage the Compliance Framework of the Company in preventing any non-compliance related incidents and to mitigate any non-compliance risks by raising compliance awareness among all the staff in the company. In addition, to ensure that the necessary documentation and processes of the Company are in line with any applicable internal/external compliance guidelines and policies, as well as the monitoring of compliance risk using the key indicators.

• Maintain an effective Compliance framework and Compliance Assurance Methodology and ensure the Group's adherence to regulatory requirements.
• Assist to review and implement compliance policies, procedures, and controls to mitigate regulatory risks and promote ethical behavior within the organization.
• Conduct regular assessments and monitor changes in financial services regulatory requirements to identify potential compliance gaps and recommend appropriate actions.
• Provide guidance and interpretation of regulatory requirements to internal stakeholders and facilitate training programs to promote awareness and understanding of compliance obligations.
• Collaborate with cross-functional teams to assess the impact of new products, services, or business initiatives on compliance requirements and ensure proper integration of compliance controls.

Position Objective: To manage the Compliance Framework of the Company in preventing any non-compliance related incidents and to mitigate any non-compliance risks by raising compliance awareness among all the staff in the company. In addition, to ensure that the necessary documentation and processes of the Company are in line with any applicable internal/external compliance guidelines and policies which regulate with BNM, as well as the monitoring of compliance risk using the key indicators.

• Oversea the AML portfolio in managing the screening process and all AML related regulatory matters.
• Conduct compliance gap analysis to evaluate the adequacy of internal controls put in place to manage compliance risk and promptly follow up on any identified deficiencies and plans to address such deficiencies.
• Conduct effective compliance-related training for all the staff twice a year to mitigate any non-compliance risks by raising the compliance awareness.
• Ensure the Company’s policies and processes are kept up to date with relevant laws, regulations and guidelines in relation to AML/CFT, Know Your Customer (KYC) and ABC, including overseeing and implementing appropriate compliance program's
• Ensure proactive and timely identification, assessment, advice and dissemination of evolving regulatory change/practices throughout the Company across the region (with a focus on Malaysia).
• Maintain appropriate relationships with relevant regulators, authorities and independent auditors and liaise with them on audits, reporting and implementation of corrective measures.
• Oversee the completion and submission of Data & Compliance Reports to BNM.
• Conduct Annual AML/CFT Risk Assessments and ABC Risk Assessments.
• Conduct internal compliance reviews on the AML/CFT and ABAC compliance program's to identify gaps against regulations and internal policies and recommend or implement corrective measures.
• Perform management reporting to the Board, Senior Management and Group Director, Legal & Compliance on compliance risks and issues.
• Provides regulatory advisory on compliance-related matters to business units
• Undertake investigations on suspicious transactions/activities escalated to Compliance and submit STRs to BNM where necessary. Provide guidance to stakeholders concerned in regard to any follow-up actions and monitor the closure of such actions.

Position Objective: Reporting to Compliance Monitoring Manager. The role holder will be responsible for the delivery of compliance monitoring reviews and the annual Compliance Monitoring and Testing Plan. Upholding MS Amlin’s core values.

• Lead and execute routine of an end-to-end compliance monitoring review.
• Conduct short thematic reviews based on the annual compliance plan (for Malaysia and UK)
• Conduct and coordinate meetings with business units at key stages of a compliance monitoring review.
• Be responsible for the Planning, Testing, Reporting of Compliance Monitoring Reviews and Remediating Actions in accordance with the annual Compliance Monitoring and Testing Plan.
• Oversee the monitoring / tracking to closure of remedial actions and weekly reporting to Compliance Monitoring Manager and business owners.
• Training and development - delivery of on-the-job training and coaching, both technical and ‘soft’ skill for Compliance Monitoring Officer(s).

Position Objective: Compliance Testing covers AML, Sanctions, KYC (Know Your Customer) and Anti-Bribery & Corruption areas. A member of the Regional Asia Compliance Testing team involved, from a Center of Excellence in KL, in the execution of risk based Anti- Money Laundering, Sanctions and AB&C assurance reviews. This is a 2ndLine Od defense role.

• Developing & Implementing Testing Programs: Design and manage risk-based compliance testing programs to evaluate the effectiveness of internal controls and procedures.
• Executing and Documenting Tests: Execute tests of compliance controls, document findings, and manage the remediation of identified issues through verification and closure
• Policy Development and Review: Draft, update, and disseminate company policies and procedures to reflect current legal and regulatory standards
• Monitoring Regulatory Changes: Stay informed regarding pending industry changes, trends, and new regulations Reporting and Communication: Prepare timely reports on audit results and compliance metrics (KPIs, KRIs) for senior management and relevant regulatory agencies.
• Employee Training: Deliver and coordinate employee training on compliance-related topics, policies, or procedures to foster a strong "compliance-first" culture
• Liaison with Authorities and Auditors: Act as a primary point of contact for external auditors, regulatory agencies, and internal stakeholders during compliance reviews and investigations.

Department: APAC KYC (Periodic Transaction Review)

Position: Senior Assistant Manager

Duration: 1stAugust 2014 to 20th March 2017

Position Description:

The Periodic Transactions Review (PTR) is a process conducted to strengthen customer due diligence to fully identify and address the AML risk associated with correspondent accounts. Periodic Transaction Review Team conducts a review of a Foreign Correspondent Banking (FCB) client’s transactional activity. The Periodic Transactions Report is a part of the Citi KYC renewal process and is used to assist with evaluating the client’s AML risk. The PTR analysis covers three months’ activity. Information gathered in the Periodic Transactions Report is used to understand the usage of the correspondent accounts by the clients and the possible associated AML risks while renewing the KYC documents for this client. It validates the accuracy of anticipated account activity, the accuracy of the risk score associated with the client, and identifies potential risk areas such as nested activity, high-risk customers, unusual activity or patterns. The Periodic Transaction Analyst is closely cooperating with AML Advisory Team and peers from Operations team.

Department: APAC AML (Transaction Monitoring Operations)

Position: Assistant Manager (Business Analyst)

Duration: 15thMay 2013 to 1st August 2014

Position Description:

Serve as the lead Remediation business analyst supporting the high number demands from a Compliance/Regulatory perspective including defining processes/solutions, enhancing sampling approaches, coordinating data sourcing, performing data quality reviews, etc. Manage and coordinate all transaction data related work – request/validation/sampling of transaction data for IMRs

Position Objective: The incumbent is responsible for the day-to-day processing of Fund Services control functions, including reconciling Asset and Cash accounts daily via TLM to ensure positions between the ledger and the relevant custodian agree. As a control function, the breaks on the reconciliations need to be kept to a minimal level to ensure accurate data is being maintained.

Department: Equity Finance Collateral

Position: Senior Global Support Executive

Duration: 1stAugust 2011 to 31st December 2011

Position Description:

Collateral Exposure Management Equity Finance Team, which is a new migration from London. In this team, specialized as a senior analyst to manage the daily exposures and the collateral movements in the bank and ensure the bank is not exposed at the end of the day's business. I was part of the migration of this new process by attending a 3-month migration training at Canary Wharf London to migrate this process back to Kuala Lumpur.

Department: Equity and Fixed Income Post Settlements

Position: Senior Global Support Executive

Duration: 1stApril 2010 to 1st August 2011

Position Description:

Equity & Fixed Income Post Settlements team, which is a migration from London. In this team, specialized as a Senior Executive in Interest Claims for Equities & Fixed Income products and also handled the Cash Reconciliation & Partial Overdue for the Fixed Income and Equities process.

Department: Securities Fixed Income Settlements

Position: Senior Global Support Executive

Duration: 10thMarch 2009 to 1st April 2010

Position Description:

Fixed Income settlements team served as a Senior Executive to process settlements for trades Settlement T+1 and failed trades for bonds. Handling settlement with international depositories / custodians (e.g. Clear stream, Euro clear, DTC or Fed wire).

Department: Securities Equities Settlements

Position: Senior Global Support Executive

Duration: 1st December 2007 to 10th March 2009

Position Description:

International Settlements Team, which deals with equity products and settlements. Maintained liaisons with various clients from across Europe and UK regarding failing trade settlements. I was part of the migration of this new process by attending a 2-month migration training at Canary Wharf London to migrate this process back to Kuala Lumpur. Was a SME in facilitating the Remigration of a specific queue in this team to Manila by preparing the training procedures & the training modules. Been the core person in monitoring the training & also preparing the training skill matrix for each of the staff in Manila.

Department: HBUS Auto Finance Application Taking (Contact Center)

Position: Global Support Executive

Duration: 5th December 2005 to 1st December 2007

Position Description:

Dealing with auto loans applications for US customers. Submitting loan application for refinance and new auto loans via calls and handling enquiries on auto loans Handling Inbound call for the applications and providing prompt customer’s service. Handling Inbound call for the applications and providing prompt customer service. Had also handled process training and other system migration related process from the Business Area. Also, handle escalation calls and supervisory level calls. Served as a trainer and a Subject Matter Expert for the team.

Process Migrations Involved In HSBC Global Banking & Markets

• International Settlements Equity (New Migration)- 2 Months Onshore Process Migration Training in HSBC Canary Wharf, London (12.01.2008 – 28.02.2008)
• Fixed Income Settlements (Phase 2) - Offshore Migration in KL (2009)
• Post Settlements (Fixed Income & Equity New Migration) - Offshore Migration in KL (2010)
• Post Settlements (Fixed Income & Equity New Migration) - Offshore Migration in KL (2010)
• Equity Finance Exposure Management Collateral (New Migration) 2 Months Onshore Process Migration Training in HSBC Canary Wharf, London (03.09.2011 – 29.10.2011)