Yang Berbahagia Dato’ Dr. Punitha Silivarajoo
Wakil-wakil Pertubuhan Bukan Berasaskan Keuntungan,
Hadirin hadirat yang dihormati sekalian,
Assalamualaikum, salam sejahtera dan selamat tengahari semua.
1. Bagi pihak SubCommittee for Non-Profit Organisation (SCONPO), saya amat berbesar hati mengalu-alukan Yang Berhormat Tuan Liew Chin Tong, Timbalan Menteri Kewangan, selaku Tetamu Kehormat, para jemputan serta semua peserta ke Simposium Kebangsaan Pertubuhan Bukan Berasaskan Keuntungan 2026. Kehadiran para pemimpin Non-Profit Organisations (atau NPO) bersama wakil agensi pengawal selia dan penguatkuasaan, institusi kewangan, serta rakan strategik amat bermakna. Pertemuan kita di Auditorium Tun Dr Siti Hasmah pada hari ini mencerminkan semangat kerjasama yang kuat antara Kerajaan dengan sektor NPO – semua berlandaskan matlamat bersama untuk memelihara integriti, akauntabiliti dan keyakinan terhadap sektor NPO di Malaysia.
Sebelum meneruskan ucapan aluan, izinkan saya menyampaikan ucapan seterusnya dalam Bahasa Inggeris agar mesej dapat disampaikan dengan lebih tepat dalam konteks persidangan ini.
Ladies and gentlemen,
2. Today’s Symposium is not just about compliance. It is about awareness, preparedness and action. Throughout the programme, we will examine international expectations, terrorist financing risks, governance challenges and tax requirements. More importantly, we will focus on practical safeguards needed to protect the mission, funds and reputation of NPOs.
3. By the end of the programme, we hope every NPO present here will leave with a clearer understanding of its obligations, the risks it may face and the actions it can take. Our aim is simple: to turn awareness into action, with practical safeguards that every NPO can take home, put to work and embed in its everyday governance.
Ladies and gentlemen,
4. The importance of today's discussions stems from the unique role NPOs play in society. NPOs hold a special position of public trust. They mobilise generosity and support charitable, religious, educational and humanitarian causes. At the same time, their ability to operate quickly and across borders may also expose them to abuse. Funds may be diverted, their final use may be difficult to trace, and online donors may not always be known to the organisation.
5. Terrorist financing does not always involve large or obviously suspicious transactions. It may involve small amounts from legitimate sources, channelled through activities that appear charitable. An NPO may be created as a front, infiltrated by individuals with harmful intent or unknowingly misused through its donors, partners, beneficiaries or programme arrangements.
6. NPOs must therefore understand the wider terrorist financing risks. Cross-border networks, intermediaries, digital channels and weak governance may be exploited. This means knowing who you are dealing with, who ultimately receives the funds and whether targeted financial sanctions may apply.
7. As regulators, we should not assume that all NPOs pose the same level of risk. NPOs are not financial institutions, and we must not treat them as though they were. Their purposes, sizes, funding structures and operating environments differ. Consistent with FATF Recommendation 8, our measures must be focused, proportionate and risk-based, while allowing legitimate charitable activity to continue.
8. Let me put it simply: Safeguarding the NPO sector is not about limiting its good work. It is about protecting that work from abuse. This is why NPOs’ awareness through today’s Symposium matters. Risk awareness is not an accusation against the sector - It is in fact a form of protection. It helps an organisation to recognise warning signs, ask better questions, maintain a clear trail of funds, and strengthen oversight by its Management or Council Members.
Ladies and gentlemen,
9. Understanding risk is the foundation of an effective and proportionate response. We cannot safeguard the sector unless we first understand where vulnerabilities exist and how they may be exploited. FATF expects countries to demonstrate a clear understanding of their risks including those affecting the NPO landscape. For this purpose, Malaysia’s Non-Profit Organisation Risk Assessments, or NPORAs, were undertaken periodically by the NCC. It provides us with a common national understanding of the terrorist financing risks affecting the NPOs within our country.
10. No single agency sees the entire picture. Thus, NPORA brings together regulators, registrars, law enforcement agencies, the financial intelligence function, financial institutions, and the NPO sector itself. By combining these perspectives, we can assess risks more accurately and direct attention where it is most needed. Importantly, NPORA recognises the distinct social purpose and operating characteristics of NPOs. It considers the threats and vulnerabilities relevant to the sector, together with the measures already in place to counter or reduce those risks.
11. The latest NPORA 2024 assesses Malaysia’s overall net NPO terrorist financing risk as “MEDIUM”. This calls for continued vigilance, as the overall rating does not mean that all NPOs face the same level of risk. Exposure varies according to an NPO’s activities, funding channels, locations, and counter-party relationships. The value of NPORA lies not merely in the assessment itself, but in how we use its findings. It helps regulators focus their efforts where risks are greatest, while giving NPOs a clearer understanding of the safeguards needed to protect their organisations and the communities they serve.
Ladies and gentlemen,
12. This brings me to SCONPO. Established under the NCC, SCONPO brings together the authorities responsible for overseeing different parts of the NPO sector. Member agencies use this platform to coordinate, share information, engage with NPOs, and develop proportionate responses to identified risks. In this regard, Labuan FSA is honoured to chair SCONPO for a two-year term since last year and ending in February 2027. Although Labuan FSA oversees the smallest segment of Malaysia’s NPO sector, we take this responsibility seriously. We contribute our international regulatory perspective, strengthen cooperation among agencies and support a more consistent and practical approach across the national NPO landscape.
13. Under the NCC Roadmap 2024–2026, SCONPO member agencies are implementing initiatives to strengthen regulatory adequacy, supervisory effectiveness, threat awareness, governance and awareness outreach. At the recent SCONPO Workshop which was inaugurally held in Labuan in mid-August, members discussed how policy and law-enforcement insights could be effectively applied in the supervision of NPOs. Ultimately, these initiatives are not pursued for compliance alone. They are intended to build a stronger, more resilient and more trusted NPO sector across Malaysia.
14. Today’s Symposium takes this effort a step further by bringing NPOs directly into this conversation. It provides a platform for open dialogue on practical challenges and workable safeguards – safeguards that prevent abuse without obstructing genuine charitable, and community works by the NPOs.
Ladies and gentlemen,
15. Our collective efforts in the past till present have produced meaningful progress and this was reflected in Malaysia’s latest Mutual Evaluation. The 2025 Mutual Evaluation recognised Malaysia’s strength in preventing terrorists and terrorist organisations from raising, moving and using funds. This includes measures to prevent the abuse of the NPO sector. In this regard, Malaysia achieved a Substantial level of effectiveness for this particular aspect under Immediate Outcome 10.
16. This achievement reflects the collective efforts of many: the relevant agencies, financial institutions and NPOs themselves. Previously identified gaps were addressed through stronger policies, tighter coordination, better info-sharing and sustained engagements with the market. Nevertheless, a positive Mutual Evaluation result is not the end of our journey. A Substantial rating is not the finishing line - it recognises how far we have come and reminds us of our responsibility to go even further.
17. The current NCC Roadmap will continue to support ongoing initiatives, while the incoming successor roadmap will address the remaining post-Mutual Evaluation gaps and preserve the progress already achieved. We must also prepare for emerging risks associated with digital fundraising, crowdfunding, social-media appeals, virtual assets and cross-border programme delivery. As the operating environment evolves, so must our safeguards, awareness and partnerships with one another.
18. To sustain this good progress and strengthen public trust, regulators and NPOs must work hand in hand, guided by good governance, transparency and accountability. Here, I would highlight three practical principles for every NPO to appreciate:
- First, understand your own risk. Consider where you operate, how you raise and transfers funds, and who your donors, partners and beneficiaries are.
- Second, strengthen your governance oversight. Boards, Councils and Management Committees should understand significant funding flows, question unusual arrangements and ensure that concerns are properly escalated.
- Third, follow both the money and the programme. Maintain clear records showing where funds came from, how they were transferred, who received them and how they were used. Apply proportionate due diligence to key donors, partners, agents and beneficiaries. And do remain alert to relevant financial sanctions and warning signs of potential misuse.
19. NPOs should also communicate openly with regulators and financial institutions. Clear information about an organisation’s purpose, governance, funding and overseas activities helps secure access to financial services and reduces unnecessary de-risking. Transparency strengthens confidence among regulators, banks, donors, beneficiaries and the public.
20. The responsibility does not rest with NPOs alone. Regulators must provide practical guidance and apply measures proportionate to risk. Financial institutions should manage identified risks without treating the entire sector as high risk. Meanwhile, law enforcement agencies should continue to share timely information on threats, networks and methods of NPO abuse. In short, everyone has a role to play here.
21. As Chairman of SCONPO, I reaffirm our commitment to work closely with member agencies and the NPO sector. No regulator, financial institution, law enforcement agency or NPO can address terrorist financing alone. Our shared objective is clear: enable good work, protect it from abuse and preserve public trust. By working together, we can safeguard national security while empowering NPOs to continue serving those who need them most.
22. With that shared responsibility in mind, let us make today a working forum, not simply a listening session. Ask difficult questions, share the realities on the ground and identify at least one practical improvement your organisation can take forward. Let us leave with more than information—with greater clarity and readiness to act. Ultimately, this symposium will be measured not by what is said in this auditorium, but by what changes after we leave it.
23. Before I conclude, allow me to record my sincere appreciation to our Guest of Honour, Yang Berhormat Tuan Liew Chin Tong for honouring us with his presence, to the Suruhanjaya Syarikat Malaysia for graciously hosting us; and to all participating agencies, speakers, panelists, NPO representatives and organising committee members. Your commitment, expertise and spirit of collaboration have made today’s symposium both possible and meaningful.
Before I pen off, allow me to close with a Malay pantun….
Burung camar terbang di Labuan
Kapal berlabuh di tepi pantai
Integriti teguh menjadi pegangan
NPO berbakti, amanah ditunai.
With that, wishing you all a productive Symposium today.
Thank you.