SAFEGUARDING INTEGRITY: UNDERSTANDING AND APPLYING MALAYSIA’S ANTI-BRIBERY LAWS
This two-day seminar provides a comprehensive and practical overview of Malaysia’s anti-bribery and corruption regulatory framework. Participants will explore the core provisions of the MACC Act 2009 and examine how it interacts with supporting legislation such as the Penal Code, AMLA 2001, Companies Act 2016, and the Whistleblower Protection Act 2010—forming a rigorous multi-layered enforcement ecosystem.
Special focus is given to Section 17A Corporate Liability, including the legal expectations surrounding “adequate procedures,” as well as organizational accountability. Participants will also be guided through the transition to ISO 37001:2025, with clear insight on how the new Anti-Bribery Management System (ABMS) standard aligns with Malaysia’s T.R.U.S.T. principles.
Through case studies, workshops, and scenario-based analysis, attendees will learn how to identify bribery risks, implement internal controls, manage third-party vulnerabilities, and cultivate ethical leadership to protect their organizations from legal, financial, and reputational harm.
Who Should Attend
Suitable for professionals responsible for governance, compliance, oversight, business operations, and decision-making:
-
-
Compliance Officers & Managers
-
Legal Counsel & In-House Lawyers
-
Risk Managers & Internal Auditors
-
Company Secretaries
-
Heads of Department & Senior Managers
-
Procurement & Supply Chain Managers
-
Sales & Business Development Managers
-
Finance & Treasury Managers
-
Human Resources Managers
-
Project Managers & Engineers
-
LEARNING OUTCOMES
By the end of this programme, participants will be able to:
-
Understand Malaysia’s anti-bribery legal framework and the roles of key enforcement agencies.
-
Interpret offences and legal definitions under the MACC Act, including penalties and statutory defences.
-
Analyse corporate liability under Section 17A and evaluate the effectiveness of “adequate procedures.”
-
Recognize the investigative powers of MACC and the relevance of whistleblower protections.
-
Understand ISO 37001:2025 requirements and how ABMS supports the Section 17A defence.
-
Apply the T.R.U.S.T. framework to build a robust and defensible anti-bribery compliance programme.
-
Identify bribery risks and execute effective due diligence, monitoring, and internal control strategies.
-
Promote ethical leadership and strengthen internal whistleblowing and integrity culture.
WHY ATTEND?
✔ Protect Your Organization & Leadership
Understand how corporate liability works and what measures are legally required to defend your company and senior management.
✔ Strengthen Compliance With Global Standards
Learn how ISO 37001:2025 integrates with Malaysia’s T.R.U.S.T. framework for a robust Anti-Bribery Management System (ABMS).
✔ Reduce Bribery Exposure Across All Functions
Gain tools to identify red flags, manage high-risk third parties, and conduct effective due diligence.
✔ Build an Ethical Workplace Culture
Discover how leadership, communication, and structured reporting channels promote integrity from top to bottom.
Course Content
DAY 1: LEGAL FOUNDATIONS, OFFENCES & ENFORCEMENT
ICE-BREAKER
Short group introduction on integrity challenges in the Malaysian business environment.
SESSION 1: Introduction to Anti-Bribery Laws in Malaysia
- Malaysia’s Anti-Corruption Landscape
- Impact of corruption on governance, business continuity, and society
- Malaysia’s national anti-corruption strategy & global commitments (UNCAC)
- Primary Legislation: MACC Act 2009
- Structure & purpose of the Act
- Role, powers & jurisdiction of MACC
- Supporting Legislation & Their Interplay
- Penal Code (Sections 161–165): Public sector bribery
- AMLA 2001: Tracing, freezing & seizing illicit proceeds
- Companies Act 2016: Director duties, internal controls, governance expectations
- Whistleblower Protection Act 2010: Rights, limitations, protections
- Multi-Agency Enforcement
- Collaboration between MACC, PDRM, Bank Negara Malaysia & regulators
- Examples of coordinated investigations
Group Activity: Mapping Malaysia’s enforcement ecosystem
SESSION 2: Deep Dive into the MACC Act 2009 (Part 1)
Individual Offences, Definitions & Defences
- Section 16 – Soliciting/Giving Gratification
- Section 17 – Bribery of Public Officials
- Section 18 – Using Office for Gratification
- Section 23 – Abuse of Position
- Key Legal Definitions
- “Gratification”
- “Agent”
- “Public Body”
- Establishing “corrupt intention”
- Penalties: imprisonment, fines & asset forfeiture
- Statutory defences under the Act
- Current case studies & prosecution trends
SESSION 3: Corporate Liability under Section 17A
- Understanding corporate liability
- Who qualifies as an “associated person”?
- Burden of proof & the “adequate procedures” defence
- Deemed liability for directors & top management (Section 17A(3))
- Related Offences: false claims, failure to report bribery
- Penalties: company fines & management imprisonment
- Case examples of corporate enforcement
Group Activity: Section 17A case analysis
SESSION 4: Investigation Powers & Enforcement Mechanisms
- MACC Investigation Powers
- Section 29 – Presumption of corruption
- Section 50 – Inspection of bank accounts
- Search, seizure, arrest powers
- Role of other agencies in investigations
- Whistleblower protection & reporting channels
- How investigations progress in real-world scenarios
End of Day 1
DAY 2: COMPLIANCE, RISK MANAGEMENT & ETHICAL CULTURE
SESSION 5: ISO 37001:2025 – Building a Certifiable ABMS Framework
- Purpose & benefits of an Anti-Bribery Management System (ABMS)
- How ISO 37001:2025 supports Section 17A compliance
- Core elements:
- Context & leadership
- Risk assessment
- Operational controls
- Monitoring & continual improvement
Group Activity: Gap analysis against ISO 37001:2025
SESSION 6: Adequate Procedures – Applying the T.R.U.S.T. Principles
- The legal foundation of “adequate procedures”
- Detailed review of the T.R.U.S.T. pillars:
- Top-Level Commitment
- Risk Assessment
- Undertake Control Measures
- Systematic Review, Monitoring & Enforcement
- Training & Communication
- Implementation strategies & common pitfalls
- Preparing for audits & compliance assessments
- T.R.U.S.T. Self-Assessment Checklist
Group Activity: Designing a T.R.U.S.T.-aligned compliance roadmap
SESSION 7: Bribery Risk Identification & Mitigation
- Recognizing bribery red flags
- Third-Party Risk Management
- Agents, intermediaries, JV partners, consultants, suppliers
- Due diligence frameworks: screening, onboarding & monitoring
- Contractual protections: anti-bribery clauses & audit rights
- Monitoring strategies & escalation paths
- Sponsorships, donations & CSR misuse risks
- Internal bribery risk mapping exercise
Group Activity: Third-party risk mitigation scenario
SESSION 8: Fostering an Ethical Culture
- Ethical leadership: tone from the top & middle
- Behavioural drivers of misconduct
- Effective reporting channels & whistleblower support
- Building psychological safety
- Sustaining ethical performance & culture metrics
End of Day 2
Enquiry
Or Call Us : +6016 338 2229
Course Schedule
Date: 2 Days
Time: 9 AM – 5 PM
Course Fee
Our course is HRDF claimable.
Contact us to claim for promo rate.
Location
In House Available or At Our Training Centre located :
Axon Consultancy Sdn Bhd
No. 2-2, Plaza Usahawan Genting Kelang,
Jalan Danau Niaga 1, Taman Danau Saujana,
53300 Kuala Lumpur.
Certificate
- Participants will receive a Certificate of Completion upon full participation in the programme.
Registration
About The Trainer & Programme
To know more about our trainer click here
Click the buttom below to download the brochure.
Enquiry
Or Call Us : +6016 338 2229