National Money Laundering and Terrorism Financing Risk Assessment 2017

National Money Laundering (ML) & Terrorism Financing (TF) Risk Assessment (NRA) 2017

Agenda
 Overview of National Risk Assessment  Results of Threat/Crime & Terrorism Financing Assessment  Results of Sectoral Assessment  Results of Non-Profit Organisation Assessment  Post NRA 2017

National Risk Assessment – Why?
International Standards
Malaysia National Risk Assessment  Conducted on a 3-year cycle - effective system in identifying, assessing and understanding ML/TF risks for the country  Foundation for robust risk-based national strategies and policies to combat ML/TF risk

• Coordinated actions and efficient allocation of resources among domestic stakeholders
• Enhancement of risk based approach across public and private sectors
  FATF Recommendation 1
   Identify, assess, and understand the ML and TF risks for the country, and should take action, including designating an authority or mechanism to coordinate actions to assess risks, and apply resources, aimed at ensuring the risks are mitigated effectively.  Apply a Risk Based Approach to ensure that measures to prevent or mitigate ML and TF are commensurate with risks identified.  Require FIs and DNFBPs to identify, assess and take effective action to mitigate their ML and TF risks. FATF Immediate Outcome 1  ML and TF risks are understood and, where appropriate, actions coordinated domestically to combat ML and the financing of terrorism and proliferation.

Overview of Assessment Scope & Methodology Non-Profit Organisation Data Points
I. Domestic Threat (ML)
II. Foreign Threat (ML)
III. Terrorism Financing Threat
Case Studies Independent
Reports
Statistical
Data
Perception
Surveys
Expert Views
Threats Risk Assessment Sectoral Risk Assessment
I. Financial Sector
II. Non-Financial Sector
III. Legal Persons & Arrangements
Interconnection between threat and sectoral vulnerabilities Labuan Offshore Risk (by Labuan FSA) Proliferation financing (Iran, North Korea) Results : Net Risk after considering effectiveness of control measures Scope Ongoing 2018 initiatives

Threat (Crime), Terrorism & Terrorism Financing Risk Assessment Results Control Effective Measures Ineffective Increasing Inherent Risk Net Risk High Medium High Medium Low 21 Serious Crimes + T & TF Control effectiveness is relative to the inherent risk : higher risk requires greater control measures

Weak
 Onshore Money
Brokers*
 Insurance
Intermediaries*
 Labuan Capital Market*
 Labuan Money Brokers
(TF)
 Other Financial
Services Providers*
 Labuan Money
Brokers (ML)
 Jewelers (TF)
 Jewelers (ML)
Marginal
 Labuan Insurers*
 Labuan Banks*
 Estate Agents (TF)
 Cosecs (TF)
 Trust Companies (TF)
 Labuan Trust
Companies (TF)
 Lawyers (TF)
 Accountants (TF)
 E-Money and Non￾Bank Cards*  Non-Bank Financial Institutions*  Estate Agents (ML)  Cosecs (ML)  Trust Companies (ML)  Labuan Trust Companies (ML)  Lawyers (ML)  Accountants (ML) Acceptable  Gaming Outlets (TF)  Insurers*  Capital Market (TF)  Gaming Outlets (ML)  Banks (TF)  Capital Market (ML)  Money Services*  Banks (ML) Strong  Casino (TF)  Casino (ML) Low Medium Medium High High Sectoral risk assessment results: Net ML & TF Risk Rating

• Both ML & TF
  Control Measures
  Inherent Risk
  Net Risk Low Medium Medium High High

NPO Assessment Results
2,040
0 1,000 2,000 3,000 4,000
LFSA (As at 2016)
BHEUU (As at 2014)
SSM (As at 2016)
ROS (As at 2015)
60,286
(95.5%)
(0.58%)
(0.05%)
(3.8%)
Number of NPOs according to regulators Risk Focus: Sub-sectors and Characteristic Possible usage of NPO for TF purposes (based on Suspicious Transaction Report (STR) information)

• Donations from
  public to NPOs
• Cash courier
• Fund transfer
• Possible funding individuals to conflict zone
• Funds were transferred to various
  individuals
  RAISING
  MOVING
  USING
  Total No. of NPOs: 62,724
  Charity
  Fraternal Others
  Assets
  Religious
  Cultural Educational
  % of GDP
  Population 31.3 million
  17,614
  2,877
  RM34 bil
  11,957
  29,331
  3.1%
  Classification No. of
  NPOs
  Risk
  Ratings
  Sub-sectors Religious
• Worshippers Society
• Management Committee
  9,035 MH
  MH
  M
  Charity
• Members Welfare
• Societal Welfare
  9,075 M
  MH
  M
  Sub-sets
  Characteristics
• Received TF intelligence
• High cash intensity in asset
• High cash transaction
• Have operations in HiRA
• Have transactions with HRA
  2,924
  3,545
  Malaysia NPO Landscape
  HRA : High Risk Area

High Risk Crimes, Terrorism & Terrorism Financing

High Risk Crime - Fraud
Inherent Risk (High) Control Effectiveness (Marginal) Ranked 1st of 21 serious crimes Ranked 1st of 21 serious crimes. However, not commensurate with high inherent risk  Ranked either 1st or 2nd in 11 out of 13 risk indicators involving:
 Investigations
 STRs
 Foreign threats
Main driving factors
 Ranked either 1st or 2nd in 10 out of 14 AML indicators involving:
 Enforcement actions
 Prosecutions
 Judiciary
 Perceived to be relatively ineffective in combating the crime (10th)  International nature of fraud cases – challenges for domestics and cross jurisdiction coordination  Illegal financial scams operators exploit gap in enforcement – various legislations overseen by different law enforcers  Abuse of financial systems – rampant use of bank accounts and mule account holders in committing fraud and laundering of proceeds

High Risk Crime - Smuggling Inherent Risk (High) Control Effectiveness (Marginal) Ranked 2nd of 21 serious crimes Ranked 5th of 21 serious crimes.  High investigation:
 3 rd in both number and amount involved in cases  Large amount involved in STRs reported by RIs (2nd)  Perceived to be high risk (4th), high connection with other crimes (3rd) and foreign threat (3rd) Main driving factors  High ML enforcement actions:
 5 th in amount involved in ML cases  6 th in ML investigation  High ML prosecution actions (4th)  Perceived to be relatively ineffective (11th)  Common items being smuggled:
 Into Malaysia – consumables & electronic goods, alcohol, tobacco, mobile phones, firecrackers, rice  Out of Malaysia – electronic products, rubber tyres  Mostly perpetrated by crime syndicates – abused the long and porous border & possibly assisted by complicit officials

High Risk Crime - Corruption Inherent Risk (High) Control Effectiveness (Marginal) Ranked 3rd of 21 serious crimes Ranked 4th of 21 serious crimes.  High investigation:
 6 th in number and 5 th in amount involved in cases  High STRs reported by RIs  4 th in number and 5th in amount involved  Perceived to be the highest risk crime & most connected with other crimes Main driving factors  High ML enforcement actions:
 1 st in amount seized & 3rd in amount frozen  2 nd in amount involved in ML cases  5 th in ML investigation  High ML prosecution actions (2nd)  Perceived to be 2nd most ineffective  Offenders of corruption crime (2014-2017) : proportional ratio between public officials (48%) and civilians (52%)  2014 – 2016 : Approximately 50% of arrested civil servant below 40 year-old  Weakening perception of corruption in the country – Transparency International : 2014 (51st), 2015 (54th), 2016 (55th), 2017 (62nd)

High Risk Crime – Illicit Drug Trafficking Inherent Risk (Medium High) Control Effectiveness (Weak) Ranked 4nd of 21 serious crimes Ranked 8th of 21 serious crimes.  High amount involved in cases investigated (6th)  Perceived to be high risk (5th) and foreign threat (1st) Main driving factors  High ML investigation (1st)  Absence of ML prosecution and conviction  Perceived to be most effective  Geographical location of Malaysia - foreign source of drugs transiting into and/or from the country  Expanding drugs market in Malaysia – number of new users detected daily: 2016 (64), 2017 (49)  Perpetrated by domestic or international organised crime syndicates

High Risk Crime – Organised Crime Inherent Risk (Medium High) Control Effectiveness (Marginal) Ranked 7th of 21 serious crimes Ranked 7th of 21 serious crimes.  Relatively high investigations (5th) and amount involved in STRs (7th) Main driving factors  High ML enforcement actions:
 4 th in ML investigations  2 nd in IP with freezing & 6th in amount frozen Net risk qualitatively raised from Medium High to High due to:

• Most of the serious crimes are perpetrated by organised crime groups.
• Lower data indicators which do not reflect actual risk level due to enforcement actions taken against individuals within an
  organized crime syndicate for their corresponding predicate crimes instead of the relevant regulation on organized crimes.  Main challenges faced in combating the crime:
   Enforcement scope limited by definition of law: Serious offence of organised crime = offence punishable by imprisonment of 10 years or above (international standard is 4 years)  Complicity of public officials : case of senior police officers offering protecting racket to crime groups  Fear instilled in law enforcers : burning of property/vehicles, shootings

Inherent Risk (Medium High) Control Effectiveness (Acceptable)

• Porous land and sea border enable transiting of value
  and terrorists between Malaysia and neighboring countries.
• Large and potentially sympathetic Muslim population
• Increased IS threat due to affiliation of Malaysia’s
  militants with the Salafi Jihadi/Wahhabi ideology Main driving factors  Intense enforcement by PDRM’s Special Branch  Success in preventing terrorist attacks and dismantling terrorist groups
• No evidence of terrorist financing being linked to extortion, robbery, smuggling, fraud or drugs
• Pew Research Centre : 11% Malaysian show favourable attitude towards IS (Lebanon 1%, Jordan 3%, Palestinian 6%,
  Turkey 5%, Indonesia 9%).
• 95-98% of Malaysians recruited via social media and online messaging apps.
• Malaysian response to the ideological threat posed by jihadist-Salafism has not been as equally vigorous or successful
  as its operational responses. (The evolution of jihadist-Salafism in Indonesia, Malaysia and The Philippines, and its impact on security in Southeast Asia, 2016). T & TF No. of IP (predicate) 76 No. of attempted attacks Value of STRs RM643m No. of STR; No. of STR foreign 534 ; 80 No. of arrests 260 No. of designations 45 No. of IP (TF) 25 No. of prosecution 20 No. of conviction 6 T & TF Terrorism & Terrorism Financing – Medium High Risk

Main Sectors

Sectoral Summary Report:
Banking
Net TF Risk Medium High
Net ML Risk High
Inherent TF Risk Medium High Inherent ML Risk High Acceptable Control

1. Acceptable level of market entry control and
   procedures.
2. Acceptable level of RIs’ Internal Controls i.e.
   improved quality and quantity of STRs and minor gaps in compliance and risk management functions for some RIs Key Contributors (Controls):
   Observations:
3. Highest value of transactions (188 billion
   transactions amounting to RM356 quadrillion).
4. Highest cash transactions (737 million transaction
   valued at RM260 trillion).
5. Provides high risk products/ services (e.g. CASA,
   trade finance, IFT, foreign exchange).
6. Highest number of customers (72 million).
   Note:

• Banking sector has the largest asset size (RM2.9 trillion) across
  all sectors
• TF risk rated at Medium High due to lower score on ‘likelihood of
  TF occurring” compared to ML Key Contributors (Inherent Risk):
  Control Measures
  Conv FO A
  Islamic FO A
  Islamic LO A
  Conv LO A
  Investment A
  DFI A
  Int Islamic A
  Labuan Banks M
  Inherent Risk
  ML TF
  Conv LO H H
  Conv FO H MH
  Islamic LO H H
  Investment MH MH
  DFI MH MH
  Islamic FO M M
  Labuan Banks L L
  Int Islamic L L
  Net Risk
  ML TF
  Conv LO H H
  Conv FO H MH
  Islamic LO H H
  Investment MH MH
  DFI MH MH
  Islamic FO M M
  Labuan Banks M M
  Int Islamic L L

1. Highest number and value involved in relation to
   both ML and TF investigations and prosecutions:

• ML: Current and savings accounts most
  commonly frozen & seized in investigations.
• TF: Noticeable increase in the usage of bank
  accounts to raise and move funds.

2. As at 2016, losses involving mule accounts =
   RM500 million (>13,500 cases investigated)
3. Associated with fraud, corruption, tax evasion, illicit
   drug trafficking, smuggling, and insider trading/market manipulation.

Sectoral Summary Report:
Capital Market Intermediaries Net TF Risk Net ML Risk Medium High Inherent TF Risk Inherent ML Risk Acceptable Control

1. Acceptable level of market entry control and
   procedures.
2. Acceptable level of internal controls by RIs
   reflected by minor gaps in established AML/CFT compliance programme for some RIs in subsector Key Contributors (Controls):
   Observations:
3. All products offered by capital market intermediaries
   are assessed as higher ML/TF risk exposure.
4. Access to capital market products via non-face-to￾face channels i.e agents and electronic delivery
   channels increase ML / TF vulnerabilities
5. High number of transactions facilitated (82% of total
   transactions) by capital market intermediaries to both local and global clients.
6. Relatively high number of customers identified as
   higher ML risk; while TF risk is assessed as low. Key Contributors (Inherent Risk):
   Control Measures
   FMUTC A
   Stockbroking A
   Derivative
   Broking A
   Inherent Risk
   ML TF
   FMUTC MH M
   Stockbroking MH M
   Derivative
   Broking M M
   Net Risk
   ML TF
   FMUTC MH M
   Stockbroking MH M
   Derivative
   Broking M M
7. ML threats generally lower than other financial
   sectors.
8. Mostly associated with insider trading/market
   manipulation and fraud. Isolated case of corruption proceeds laundered through stockbroking firm. Medium High Medium Medium FMUTC: Fund Management and Unit Trust Companies

Sectoral Summary Report:
Insurance and Takaful Operators (ITO) Net TF Risk Medium Net ML Risk Medium Inherent TF Risk Medium Inherent ML Risk Medium Acceptable Control

1. Acceptable level of market entry control and
   procedures.
2. Acceptable level of RIs’ internal controls i.e. minor
   gaps in established AML/CFT compliance programme for some RIs in subsector.
3. Lower number of transactions as compared to banks
   at 102.2 mil. transactions amounting to RM91.48 billion.
4. Extensive local network i.e. highest number of
   agents at 215,552.
5. Lowest value of cash transactions at 12.3 million
   transactions amounting to RM4.4 billion;
6. Low number of higher risk customers (less than
   1% of total customer).
7. High number of ML-related STRs reported on life
   and composite insurer, but low for other sub-sectors Control Measures Life A Comp Ins A Comp T A Family T A Gen ReT A Comp ReT A Gen Re A General A Life Re A Comp Re A Labuan ITO M Inherent Risk ML TF Life MH MH Family T M M Comp T M M Comp Ins M M Comp Re L L Comp ReT L L Labuan ITO L L Life Re L L General L M Gen Re L L Gen ReT L L Net Risk ML TF Life MH MH Family T M M Comp T M M Comp Ins M M Labuan ITO M M Comp Re L L Comp ReT L L Gen ReT L L Gen Re L L General L L Life Re L L Key Contributors (Controls):
   Observations:
   Key Contributors (Inherent Risk):
8. Generally lower threat as compared with other
   financial sectors.

• Mainly ML risks rather than TF risks.

2. Several cases of civil servants purchasing insurance
   policies using proceeds from corruption.
3. Also associated with fraud and tax evasion.

Sectoral Summary Report:
Money Services Businesses
Net TF Risk Medium High
Net ML Risk Medium High
Inherent TF Risk Medium High Inherent ML Risk Medium High Acceptable Control

1. Acceptable level of market entry control and
   procedures
2. RIs’ internal control assessed as Marginal i.e.
   reflected by major gaps in established AML/CFT compliance programme for most RIs in subsector i.e. Quality of STR
3. Approx 99% of its transactions are cash-based.
4. All products offered by MSB sectors are identified
   as high risk for ML and TF
5. At-risk local network is relatively high for ML and TF
6. Relatively high number and value of STRs reported
   on the sector:

• ML (220): amounting to RM2,214 million
• TF (1): amounting to RM254 million in ‘14

5. 2 incidences of TF investigations.
   Control Measures
   Remittance A
   Money
   Changing A
   MC&R,
   MC&R&W M
   MC&W M
   Inherent Risk
   ML TF
   Money
   Changing MH MH
   Remittance MH MH
   MC&R,
   MC&R&W MH MH
   MC&W M M
   Net Risk
   ML TF
   Money
   Changing MH MH
   Remittance MH MH
   MC&R,
   MC&R&W H H
   MC&W MH MH
   Key Contributors (Controls):
   Observations:
   Key Contributors (Inherent Risk):
6. Some licensed MSB involved in illegal remittance
   activities.
7. Some delicensed MSB continued to carry on illegal
   remittance activities.

• Facilitating cross border funds transfer related to
  fraud, tax and smuggling.

3. Investigations also revealed MSB being abused to
   transfer funds in TF activities.

Sectoral Summary Report:
E Money, Non Bank Affiliated Charge & Credit Card Net TF Risk Medium High Net ML Risk Medium High Inherent TF Risk Medium Inherent ML Risk Medium Marginal Control

1. Marginal level of market entry control and
   procedures.
2. Marginal internal controls by RIs due to poor
   quality of STR reported by sector and major gaps in AML/CFT compliance programme for most of the RIs’ in subsector.
3. Types of products offered are identified as high risk
   for ML and TF
4. Products are offered through higher risk delivery
   channels via agents and electronic channels.
5. Less than 1% of customers in 2016 identified as
   higher risk (7,600 customers).
6. Relatively low number and value of STR reported on
   the sector:

• ML: 31 STRs amounting to RM240 million
• TF: None

5. 1 case of ML investigations; none for TF.
   Control Measures
   E-money
   (Large) M
   Non-bank
   Credit Card W
   Charge Card W
   E-money
   (Small) W
   Inherent Risk
   ML TF
   E-money
   (Large) MH MH
   Non-bank
   Credit Card M M
   Charge Card M M
   E-money
   (Small) M L
   Net Risk
   ML TF
   E-money
   (Large) H H
   Non-bank
   Credit Card H H
   Charge Card H H
   E-money
   (Small) H MH
   Key Contributors (Controls):
   Observations:
   Key Contributors (Inherent Risk):
6. E-money accounts created using fictitious
   identification.

• Used for criminal activities, e.g. selling
  counterfeit goods & pornographic materials.

2. Peer to peer fund transfer can be abused for ML &
   TF

• Terrorist received funds transfer through e￾money account.

Sectoral Summary Report:
Labuan Banking
Net TF Risk Medium
Net ML Risk Medium
Inherent TF Risk Low
Inherent ML Risk Low
Marginal
Control

1. Marginal level of market entry control and
   procedures
2. Marginal internal controls by RIs reflected by low
   number of STRs and major gaps in established AML/CFT compliance programme for most RIs in subsector. Despite having high product and delivery channel risks, inherent risks remain low due to:
   1.Prohibition on cash transactions (LFSSA 2010)

• Total transactions less than 1% of the Malaysian
  banking sector.
  2.Low number of higher ML/TF risk customers
• Less than 1% of Malaysian banking sector.
  3.Low number of at-risk ML/TF global networks
• 1% for ML; 5% for TF due to corresponding banking
  relationships in higher risk countries. 4.Low incidences of ML cases and none for TF. Control Measures Banks A L Conv Inv Bank M L Islamic Bank M Labuan Com Banks M L Islamic Inv Bank M Inherent Risk ML TF Banks H MH Labuan Com Banks M M L Islamic Inv Bank L Islamic Bank L Conv Inv Bank L L Net Risk ML TF Banks H MH Labuan Com Banks MH MH L Islamic Inv Bank M M L Islamic Bank M M L Conv Inv Bank M M Key Contributors (Controls):
  Observations:
  Key Contributors (Inherent Risk):

1. Pose lower ML and TF risks compared with
   onshore counterparts, mainly due to

• Low volume of transactions facilitated (< 1% of
  that for onshore banking sector)
• Prohibition of cash transactions
• Low occurrence of ML and TF activities

2. No TF threat observed during period under review.
3. Proceeds from fraud in several investigations flew
   through Labuan Banks.

Sectoral Summary Report:
Dealers in Precious Metals & Stones Net TF Risk High Net ML Risk High Inherent TF Risk Medium Inherent ML Risk Medium High Weak Control

1. Weak level of market entry control and procedures.
2. Weak internal controls by RIs reflected by absence
   of STRs reported and significant gaps in established AML/CFT compliance programme for all RIs’ in subsector.
3. Unable to determine number of higher risk customers
   due to absence of data.
4. Higher risk products identified, i.e. gold and
   diamond are of high value, easily transferrable and non-traceable.
5. Large local presence with high number of firms at
   local higher risk areas (77%).
6. High number of STR reported on – 2
   nd highest within the DNFBPs sector.
7. No STR reported on the sector involving TF.
   Control Measures
   DPMS W
   Inherent Risk
   ML TF
   DPMS MH M
   Net Risk
   ML TF
   DPMS H H
   Key Contributors (Controls):
   Observations:
   Key Contributors (Inherent Risk):
8. Jewelleries are one of the most commonly seized or
   frozen assets in investigations, mainly fraud & illicit drug trafficking.
9. No TF activities associated with DPMS during the
   period under review. However, there was past case where sanctioned individual used gold products as collateral for loans.

Sectoral Summary Report:
Casino
Net TF Risk Low
Net ML Risk Medium
Inherent TF Risk Medium
Inherent ML Risk Medium High Strong Control

1. Acceptable level of market entry control and
   procedures.
2. Acceptable internal control observed in Casino
   reflected by minor gaps in established AML/CFT compliance programme i.e. Quality of STR
3. Total cash transaction value made by casino
   account for 24% of total cash transactions value transacted by DNFBPs (2nd highest)
4. Higher risk delivery channels, i.e. use of agents
   (junkets from various jurisdictions) and offering of external advice electronically (provides anonymity to the sources of funds)
5. Higher risk products and services identified, i.e. 4
   out of 16 products/ services
6. Higher risk customers account for 0.37% out of
   total customer.
7. No investigation / prosecution on casino
8. No STR reported on the casino for TF.
   Control Measures
   CASINO S
   Inherent Risk
   ML TF
   CASINO MH M
   Net Risk
   ML TF
   CASINO M L
   Key Contributors (Controls):
   Observations:
   Key Contributors (Inherent Risk):
9. Limited case studies related to ML activities during
   the period under review.
10. Minimal likelihood of casino being abused for TF
    activities.
11. Junket operators utilised over 90% of higher risk
    facilities.

NPO Assessment

Observations – Inherent Risks (Perception Survey and SRA 2017 Data) C 3 B A High number of accounts Very high number of NPO accounts across the banks may signal multiple accounts held, the possibility of inactive NPOs continues undertaking financial transactions Classification of HR Classification of high risk NPO includes, religious, charity, social/welfare Perception of Donation and NPO as vulnerable to TF abuse Conservative Risk Approach Banks are viewed to have conservative approach to classification of risks for NPO (14 out of 61 banks rated 100% of NPO as high risks) . SRA DATA *based on 722 response based on 61 banking institutions data PERCEPTION SURVEY Overall – Medium High Rating Financial institutions generally view NPOs as high risk The perception of risks for other group of respondents are mixed *Other group of respondents: DNFBPs, LEAs, prosecutor, supervisors/regulators, judge/magistrate, others

Observation – Control Measures ADEQUACY OF LAWS STRENGTH OF MONITORING/SUPERVISON LEVEL OF COMPLIANCE EFFECTIVENESS OF ENFORCEMENT

• Most international standards
  requirements met
• Rectification of gaps from MER 2015
  necessary
• The need to comply with the new
  revision of Recommendation 8 of FATF Standards
• No of supervisors over no of higher risk
  NPOs/ NPO population varies across regulators
• No of onsite/ of site monitoring varies
• Based on current no of supervisors,
  coverage on higher risk NPOs may have been met by certain regulator
• Spectrum of annual compliance (50-
  100%)
• Level of enforcement actions vis-à-vis
  non compliance varies across regulators, depending on agencies’ approach

Post NRA
– Recalibration of National Strategic Plan

Post NRA 2017 : Recalibration of NSP Legal Framework Include additional serious offences under the Act Centralised enforcement framework for serious crimes & assets management Exempt low risk sectors/product from AMLA regime Policy & Implementation Framework Review AML/CFT policies for reporting institutions Increase supervisory activities and monitoring of at risk sectors Enhance data collection and sharing Resources & Structure Joint enforcement for high risk crimes Enhance supervisory resources & tools Awareness & Training Develop AML/CFT certification programme Enhance engagement between supervisors and law enforcement officers Strategic awareness programmes Potential initiatives – examples

NRA & The Industry

Institution Level
ML/TF Risk
Robust
Communication
& Training
Informed
Business
Decision
Efficient
Allocation of
Resources
Guided Policy &
Procedures
Formulation
Products
Markets
Front liners
Management
Compliance
Management
Information
System
Business units
Risk
Management

Thank You