# Due Diligence Checks — Counterparty, Partner, Director & Key-Hire URL: https://robocompanysecretary.com/services/due-diligence-checks/ Offered through both our brands — Robo Company Secretary and companies.com.my ## Know who you do business with. Document the checks behind your decision. Section 17A creates corporate liability for corruption by associated persons. Documented due diligence can support a wider prevention programme. Our due diligence checks start at RM 302.40 for counterparty screening, RM 518.40 for key hires and RM 734.40 for partners, delivered as a red/amber/green memo in two to five working days. Message us See what we check Counterparty, partner, director and key-hire checks. From RM 302.40. Typically 2–5 working days. Issued by AK Secretarial Companies Sdn. Bhd. 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. #### 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. #### 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. #### 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. #### 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) → The organisation's adequate-procedures defence should not be confused with the separate rules governing an individual director's or manager's liability. Obtain legal advice on the relevant statutory test and the facts; a clean screening result does not establish either defence by itself. Checks need to be proportionate to the risks and followed by action where concerns arise. Keep the decision, follow-up and ongoing review on record as part of the organisation's prevention programme. 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 enforcement guidance (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. The layers below describe checks that may be relevant. Your selected product and written quotation define the included checks. Access, consent and source availability can limit coverage; a clear search is not a guarantee that no risk exists. 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; candidate-obtained 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. Buying an existing company requires a separately agreed acquisition-review scope; the counterparty check price is not a quote for full acquisition due diligence. #### Counterparty Check From RM 302.40 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 734.40 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 518.40 Typically 3–5 working days for the core file; criminal-record certification by the candidate runs separately on the issuing authority’s timetable 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 - Certificate of Good Conduct where applicable: the candidate applies through the official process. Eligibility, official fees and processing time must be checked when applying. We brief the candidate and update the file when the certificate is available. Add-ons (optional) Extended employment history (5+ years) · International qualification verification · Deep social / online audit · Express turnaround Criminal indicators in a commercial report are not a full criminal-record clearance. Any official certificate runs separately. Core turnaround depends on consent, available records and responses from employers and institutions; unavailable checks are identified in the report. Get a quote for this check Add-on prices confirmed at quote stage based on subject scope and jurisdiction. Who does the work ### Our operator, and our company secretarial provider. Robo Company Secretary is operated by Robostrikeforce Sdn. Bhd., 202601021273 (1683370-U) . Companies.com.my is the brand of AK Secretarial Companies Sdn. Bhd., which provides our company secretarial services. Our team has incorporated over a thousand Malaysian SMEs and foreign founders since 2011. Robo Company Secretary is our plain-English brand for founders who already know what they want. Checks ordered here are done by that same team, to the same standard, and the memo is issued by AK Secretarial Companies Sdn. Bhd. Robo . Company . Secretary × Visit companies.com.my → Company secretarial provider Our team: incorporating Malaysian businesses since 2011 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 — the memo is issued by AK Secretarial Companies Sdn. Bhd., prepared by its SSM-licensed company secretaries, and there's 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 can contribute to evidence of prevention measures; it does not by itself prove the Section 17A adequate-procedures defence. 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., the company secretarial provider behind Robo Company Secretary, 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. It can support a wider prevention programme; legal sufficiency depends on the full facts. Tell us who needs checking ### Three questions. One fixed quote. We'll come back to you with a fixed quote within four working hours, and a timeline. ### You can't unwind a bad partner. You can decline one early. A few hundred ringgit. A few days. One memo. One decision. Start a check Talk to us first Offered by Robo Company Secretary, operated by Robostrikeforce Sdn. Bhd.; company secretarial services are provided by AK Secretarial Companies Sdn. Bhd.. companies.com.my →