Robo.Company.Secretary

A new service from Robo Company Secretary × companies.com.my

Under Section 17A, if your associate bribes for your benefit, you and your directors are presumed guilty.

The only legal defence is documented due diligence — carried out before the relationship started. Not a phone call to a friend. Not a Google search. A file you can put in front of MACC.

Counterparty, partner, director and key-hire checks. From RM 280. Typically 2–5 working days. Delivered by AK Secretarial Companies Sdn Bhd.

Watercolour illustration of a sealed archive box with brass clasp — the kind of due-diligence report we deliver

The four moments

You're about to make one of these decisions. Which one?

Every founder, finance lead, and HR head we've worked with has had one of these four moments. Getting it right costs a few hundred ringgit and a few days. Getting it wrong runs from a written-off invoice to directors' personal liability under Section 17A. Here's where due diligence pays for itself many times over.

Conceptual illustration: the gap between how a new customer presents and what they actually are

Extending credit to a new customer

You're about to ship RM50,000 in inventory on 60-day terms. Or sign a 12-month service contract with a new client. The salesperson is enthusiastic. The procurement contact seems reasonable. The company name sounds established.

But the company was incorporated 11 months ago. Three of its directors sit on six other companies, two of which have winding-up petitions filed against them. There's a writ for RM180,000 from a supplier filed in Shah Alam last March.

You won't see any of that on a Google search. You'll see it the day the invoice goes unpaid.

Our Counterparty Check catches this in two to three working days.

Conceptual illustration: binding your company's fate to another party — irreversibly, on presentation alone

Bringing in a new business partner

A new partner brings capital, a network, sometimes a market. They also bring everything else — past disputes, undisclosed directorships, ongoing litigation, sanctions exposure, reputational baggage.

We've seen it: founders who discover, six months after signing, that their new 30% shareholder is a respondent in an active fraud suit. Or that their "investor" is a politically exposed person with adverse media in three jurisdictions. Or that their JV partner already owns a competing entity through a nominee structure.

By then, the equity is issued. The shareholders' agreement is signed. The mess is yours to unwind.

Our Partner / Director Check maps cross-holdings, litigation and adverse media before the equity moves.

Conceptual illustration: an individual's history becoming the boardroom's exposure

Appointing a new director

Under Section 17A of the MACC Act, directors are personally exposed when a commercial organisation commits a corporate liability offence. A new director joining your board inherits — and contributes to — that exposure profile.

If they have undisclosed directorships, prior corporate failures, sanctions listings, or adverse media, they don't just risk themselves. They risk you. And the company. And every other director on the board.

Our Partner / Director Check goes deeper than CTOS alone — full SSM director mapping, litigation, PEP, sanctions, adverse media.

Conceptual illustration: believing a story written for you, by the storyteller

Hiring for a key position

Finance lead. Operations head. Senior sales. Anyone with access to your bank accounts, your customer list, your supplier terms, or your statutory filings.

Industry surveys consistently find that a meaningful share of CVs contain misrepresentation — inflated titles, exaggerated tenure, fabricated qualifications. A smaller but more dangerous share conceal something material: a prior dismissal for cause, an undisclosed directorship in a competitor, a criminal proceeding, a bankruptcy.

The reference letter the candidate hands you was written by the candidate's friend.

Our Key Hire Check verifies employment, education, qualifications, criminal record, undisclosed directorships, and references — with the candidate's written consent under PDPA 2010.

The law that changed the stakes

Section 17A, Malaysian Anti-Corruption Commission Act 2009

Since 1 June 2020, a commercial organisation in Malaysia is liable for corruption committed by any associated person — employee, agent, supplier, partner — where the corruption was carried out for the organisation's benefit. Whether or not senior management knew about it.

The penalty on conviction is a fine of not less than ten times the value of the bribe, or RM1 million, whichever is higher, or imprisonment for up to 20 years, or both. Section 17A(2) →

Directors, controllers, officers and partners involved in the management of the organisation at the time of the offence are deemed to have committed the offence themselves. A defence exists, but only one: prove the offence was committed without your consent or connivance, and that you exercised adequate procedures to prevent it.

The case law is being written right now. Two corporate Section 17A prosecutions have been brought since the law came into force — one struck out on procedural grounds in May 2026, one heading to High Court trial. No court has yet ruled on what "adequate procedures" looks like as a successful defence. You do not want your company to be the test case.

The Governance, Integrity and Anti-Corruption Centre under the Prime Minister's Office issued the Guidelines on Adequate Procedures in December 2018. Five principles, arranged as the acronym T.R.U.S.T. — Top-level commitment, Risk assessment, Undertake control measures, Systematic review, Training and communication. Guidelines on Adequate Procedures →

Due diligence on counterparties, partners, directors and key hires is exactly what Risk assessment and Undertake control measures look like in practice.

Sources: Section 17A, MACC Act 2009 (English PDF, SPRM) → · Guidelines on Adequate Procedures (English PDF, GIACC) → · SPRM official portal →

This page describes a service, not legal advice — for your specific exposure, speak to your lawyer.

What we actually check

The six layers of a real due diligence file.

A name and a Google search isn't due diligence. A CTOS report alone isn't due diligence. Real due diligence cross-checks six independent data layers, each revealing something the others can't. Here's what we look at, and what each layer tells us.

01

Identity & corporate existence

Source

SSM (Companies Commission of Malaysia)

What it tells us

Whether the company actually exists as claimed. Who really owns it. Who really directs it. What's pledged against the assets via registered charges. Three-year financial extracts. Cross-holdings to other entities and beneficial-ownership patterns.

02

Credit history & payment behaviour

Source

CTOS (Malaysia's leading credit reporting agency, regulated under the Credit Reporting Agencies Act 2010)

What it tells us

Credit score, payment patterns, CCRIS records (Bank Negara), trade references, prior defaults, litigation indicators visible at the credit-reporting layer.

03

Insolvency & litigation

Source

MyEG e-Insolvency Database (Malaysian Department of Insolvency), Malaysian court records

What it tells us

Bankruptcy status of individuals. Liquidation status of companies. Active writs, judgments, sums in dispute. Recurring defendant patterns.

04

Sanctions, PEP & adverse media

Source

UN Security Council Resolutions list, OFAC, MOHA Watchlist, PEP databases, adverse media scan

What it tells us

Whether the subject is listed on any international or national watchlist. Whether they are a politically exposed person. Whether they've appeared in adverse media in any jurisdiction we can reach.

05

Identity & document verification

Source

Direct verification of NRIC / passport / supporting documents

What it tells us

That the person you're dealing with is the person they claim to be. That the documents they've shown you are authentic.

06

People-side checks (for key hires, with written consent)

Source

Direct contact with former employers, education institutions, professional bodies; PDRM Certificate of Good Conduct where applicable

What it tells us

Whether the employment history is real. Whether the qualifications are real. Whether the references are real and independent of the candidate's own network.

Under the Personal Data Protection Act 2010, all people-side checks are carried out with the subject's written consent.

The deliverable

What you actually receive.

A stack of raw reports isn't a deliverable. It's homework. What we deliver is a one or two page memo with a clear red / amber / green call and a paragraph of reasoning. Reports attached as appendices. When you sit down to make the decision, you're reading three minutes of plain English, not three hours of database output.

1

Memo

A plain-English summary. The decision colour. Three to five lines of reasoning. The flags you should know about. The questions we'd ask before proceeding.

2

Appendices

Raw CTOS report. SSM extracts. MyEG insolvency screens. Sanctions / PEP screens. Litigation findings. Identity verification records. Everything we looked at, indexed and labelled.

3

Conversation

A 15-minute call if you want to walk through it. No additional charge, included in every check. We've read the file already, so the call is about your decision, not about explaining the data.

Three checks. Three decisions.

Three checks. Three decisions.

Each product is scoped to a specific decision. Pricing is public — from-prices below — and we quote you a fixed fee for your specific case before any work begins. No subscriptions. No retainers. Pay per check.

Counterparty Check

From RM 280

Typically 2–3 working days

For

Extending credit to a new customer. Onboarding a new supplier. Signing a service contract with a counterparty you haven't worked with before.

Includes

  • CTOS business credit report (with subject consent where required)
  • SSM company profile + registered charges
  • MyEG insolvency screen (company + directors)
  • Basic sanctions / PEP scan
  • One-page memo with R/A/G call
  • 15-minute walkthrough call

Add-ons (optional)

Director-level deep-dive · Litigation docket search · Adverse media scan · Express turnaround (24–48h)

Get a quote for this check

Partner / Director Check

From RM 680

Typically 3–5 working days

For

Taking on a new shareholder. Forming a JV. Appointing a new director. Any decision where the person becomes part of the company.

Includes

  • Everything in the Counterparty Check
  • Full SSM director mapping (cross-holdings, related entities)
  • Litigation docket search (five-year window)
  • Adverse media scan
  • Sanctions, PEP and watchlist screening (international)
  • Identity verification
  • Two-page memo with R/A/G call
  • 15-minute walkthrough call

Add-ons (optional)

Extended adverse media (10-year window) · Enhanced PEP screening · Family-network mapping · Express turnaround

Get a quote for this check

Key Hire Check

From RM 480

Typically 3–5 working days for the core file; criminal-record certification by the candidate runs separately at PDRM pace

For

Hiring for any position with access to money, customers, suppliers, statutory filings, or strategic information. Finance, ops, senior sales, executive roles.

Delivered in 3–5 working days (with candidate's written consent under PDPA 2010)

  • Employment verification (last two employers)
  • Education verification (highest qualification)
  • Professional qualifications verification
  • CTOS bureau criminal indicators
  • Undisclosed directorships / shareholdings
  • Bankruptcy & litigation (MyEG + court records)
  • Reference checks (independent of candidate-supplied contacts)
  • Light social / online open-source scan
  • Two-page memo with R/A/G call
  • 15-minute walkthrough call

Initiated alongside the core file, runs separately

  • PDRM Certificate of Good Conduct (the candidate applies via e-Konsular; RM20 official fee; PDRM vetting typically 30–90 working days). We brief the candidate on the process and update your file when it lands.

Add-ons (optional)

Extended employment history (5+ years) · International qualification verification · Deep social / online audit · Express turnaround

Honest note: full criminal-record clearance from PDRM is the candidate's to obtain — Malaysian law does not allow employers or third parties to query PDRM directly. We do everything else within the core 3–5 working day window.

Get a quote for this check

Add-on prices confirmed at quote stage based on subject scope and jurisdiction.

Two brands. One firm.

Two brands. One firm. The same team.

Robo Company Secretary and Companies.com.my are both operated by AK Secretarial Companies Sdn Bhd (Reg. No. 201101008946 (937085-D)), a Malaysian licensed corporate secretarial firm.

Companies.com.my has been the door through which over a thousand Malaysian SMEs and foreign founders have incorporated since 2007. Robo Company Secretary is our newer plain-English brand for founders who already know what they want.

Whichever door you came through, the same team, the same legal entity and the same standard does the work. Due diligence checks are offered through both — order through whichever brand you know.

Robo.Company.Secretary
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Two brands of AK Secretarial Companies Sdn Bhd

Incorporating Malaysian businesses since 2007

Questions we get asked

Things people want clarified before they commission a check.

Yes. All data sources we use are either public records (SSM, court records, MyEG), licensed credit reporting (CTOS, regulated under the Credit Reporting Agencies Act 2010), or carried out with the subject's written consent (employment, education and reference verification for key hires) under the Personal Data Protection Act 2010. For counterparty and partner checks on companies and their directors, all sources are public-record or licensed credit-reporting.

Three differences. First, CTOS is one of six data layers — by itself it misses half the picture. Second, raw reports take hours to interpret if you've never seen one; we deliver a one-page memo. Third, we stand behind the work as a licensed corporate secretarial firm — there's a real entity, real professionals, and a real conversation behind the file.

Typically 2–5 working days. Express turnaround (24–48h) is available on the Counterparty Check for an additional fee.

Yes. You're paying for the work and the file, not the conclusion. A clean check is exactly the file you want if anything goes wrong later — a green-light memo signed by a corporate secretarial firm is protective evidence of "adequate procedures" under the Section 17A TRUST framework.

For three or more checks per quarter, yes — talk to us. For everyone else, single-check pricing is simpler and cleaner.

Yes, through network partners — at separate pricing. Ask us and we'll tell you what's possible in the jurisdiction you need.

Every check includes a signed memo from AK Secretarial Companies Sdn Bhd with the date, scope, sources consulted, findings, and decision recommendation. The full appendix of raw reports is retained for seven years and reproducible on request. This is the kind of evidence Section 17A's "adequate procedures" defence calls for.

Tell us who needs checking

Three questions. One fixed quote.

We'll come back to you within four working hours with a fixed quote and timeline.

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You can't unwind a bad partner.
You can decline one early.

A few hundred ringgit. A few days. One memo. One decision.

This service is delivered in collaboration with companies.com.my →

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