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BNM RMiT Appendix 11

BNM RMiT Appendix 11: What Malaysian Banks Must Do to Detect and Stop Digital Fraud

Short answer: Appendix 11 of Bank Negara Malaysia’s (BNM) Risk Management in Technology (RMiT) policy document sets minimum fraud detection standards for retail digital banking. Banks must build a risk profile for each customer, detect and block suspicious transactions in real time, contact the affected customer within 30 minutes of a block, and update fraud rules promptly as new techniques appear.

What is Appendix 11?

Appendix 11 is the fraud detection section of the RMiT policy document (reference BNM/RH/PD 028-98), issued on September 25, 2026. The document supersedes several earlier instruments, including the Specifications on Fraud Detection Standard dated March 27, 2024. Fraud detection now sits inside the main technology risk framework, and paragraph 12.4 links the two. It requires fraud detection capabilities and rules to be updated in a timely manner when new modus operandi appear.

Who does it apply to?

Appendix 11 covers financial transactions carried out through digital services for retail customers. BNM’s RMiT FAQ (updated July 1, 2026) adds that for corporate and other non-retail segments, the controls apply on a risk-based and proportionate basis.

What does Appendix 11 require?

Area

What BNM requires

What it means in practice

Customer risk profile

A detailed profile for each customer, using demographics, geography, transaction history and behavior such as typing speed and mouse movement

Each transaction is judged against that customer’s own baseline

Real-time action

Detect and block suspicious transactions in real time, based on individual profiles

The decision happens before the money moves

Event triggers

Monitor new e-banking enrollment, new device registration, password reset, limit increase, contact detail changes and new payees

A risky event raises scrutiny of what follows

Transaction patterns

Watch for high-volume debits to new beneficiaries, sudden pattern changes, activity on dormant accounts, unusual locations and payments to suspected mule accounts

Behavior over time matters as much as any single payment

Device and identity

Detect device fingerprint changes and attempts to bypass fingerprinting, account takeover using advanced artificial intelligence tools, changes to biometric credentials, and score vulnerable customers higher

Device and identity signals feed the same risk decision

Sessions and consent

Terminate hijacked sessions, warn customers about risky applications, and obtain consent before device profiling

Digital trust extends beyond the payment

Investigation and response

Investigate by priority, verify with the customer before releasing a flagged transaction, notify immediately on a block, and make contact within 30 minutes, including peak periods

Operations must keep pace with detection

Continuous updates

Enhance rules promptly when new techniques evade detection, and review thresholds against new typologies, including those seen in other jurisdictions

Fraud controls change as fast as fraud does

Playbook

A fraud management playbook, validated at least once a year using confirmed and missed fraud

Every case feeds the next improvement

What happens if a bank has gaps?

Paragraph 12.2 sets out the consequence. A bank that has not implemented the specified digital services controls must be ready to show that its alternatives are equivalent or superior, and it must assume liability for fraud arising from the gap. Appendix 11 also encourages banks to exceed the minimum standards and keep upgrading their detection capability, so the requirements are a baseline, not a target.

Five questions to test readiness

  1. Can the bank score every digital transaction against that customer’s own profile before funds move?
  2. Does the system treat a new device, password reset, limit increase or new payee as a signal, and track what happens next?
  3. Can it detect device changes and attempts to bypass device fingerprinting?
  4. Can operations verify and contact the customer within 30 minutes, including at peak hours?
  5. How long does a new fraud rule take to move from a fraud team finding to production, and when was the playbook last validated?

How Clari5 supports Appendix 11

Clari5 provides real-time enterprise fraud risk management to 80+ banks across 30+ countries, and Chartis Research named Clari5 a Category Leader in Enterprise Fraud Solutions in its 2026 Quadrant Update.

Clari5 Enterprise Fraud Risk Management (EFRM) addresses the main Appendix 11 requirements as follows.

Appendix 11 requirement

Clari5 EFRM capability

A risk profile for each customer

Builds and maintains an individual profile from transaction history, timing, velocity, new beneficiaries and geography, and captures behavioral signals

Real-time detection and blocking

Blocks a digital transaction in the payment path, not only raises an alert

Event and pattern triggers

Treats events such as new device registration, password reset, limit increase and new payee as risk signals, and tracks the transactions that follow

Device and session risk

Uses device fingerprinting & behavioral biometrics to provide device and session signals, detect device fingerprint changes and attempts to bypass fingerprinting, and support termination of hijacked sessions

Account takeover and vulnerable customers

Detects account takeover and identity fraud and applies higher risk scores to vulnerable customer segments

Mule and external intelligence

Flags transactions to suspected mule accounts, where the bank holds the relevant account details from its own, industry or law enforcement sources

Investigation and customer contact

Case management prioritizes alerts by risk level and supports call-back verification

Rule changes and playbook

Lets fraud teams add and tune rules promptly, and feeds confirmed and missed fraud outcomes back into thresholds and the annual playbook review

Frequently asked questions

When was the updated RMiT policy document issued?

BNM issued the updated RMiT policy document (reference BNM/RH/PD 028-98) on September 25, 2026. It updates the revision BNM issued in November 2025. The effective date remains November 28, 2025, unless a provision states a different date.

How fast must banks contact customers after a blocked transaction?

Within 30 minutes of the transaction, including during peak periods (Appendix 11, paragraph 5). The bank must also notify the customer immediately when it blocks a transaction.

Does BNM require banks to use artificial intelligence for fraud detection?

No. Appendix 11 requires banks to detect account takeover and identity fraud carried out with advanced artificial intelligence tools. It does not prescribe a specific technology for detection.

Does Appendix 11 apply to corporate banking?

It is aimed at retail digital services. BNM’s FAQ says non-retail segments apply the controls on a risk-based and proportionate basis.

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About the author

Team Clari5

Fraud Intelligence