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Good
morning, ladies and gentlemen
It
is indeed a great privilege for me to be here this morning to
speak briefly on current trends and difficulties in international
trade and finance.
INTRODUCTION
The explosive growth of international financial transactions and
capital flows is one of the most far-reaching economic
developments of the late 20th century. Net private capital flows
to developing countries tripled – to more than US$150 billion a
year during 1995 to 1997 from roughly US$50 billion a year during
1987 to 1989. At the same time, the ratio of private capital flows
to domestic investment in developing countries increased to 20% in
1996 from only 3% in 1990. Hence, this has effected a shift from
the national economy to global economies in which production and
consumption is internationalised and capital flow freely and
instantly across borders.
Powerful
forces have driven the rapid growth of international capital
flows, including the trend in both industrial and developing
countries towards economic liberalization and the globalisation of
trade. Revolutionary changes in information and communications
technologies have transformed the financial services industry
worldwide. Computer links enable investors to access information
on asset prices at minimal cost on a real time basis, while
increased computing power enables them to rapidly circulate
correlations among asset prices and between asset prices and other
variables. At the same time, new technologies make it increasingly
difficult for governments to control either inward or outward
international capital flows when they wish to do so.
In
this context, perhaps financial markets are best understood as
networks and global markets as networks of different markets
linked through hubs or financial centres.
All
this means that the liberalisation of capital markets and with it,
likely increases in the volume and volatility of international
capital flows is an ongoing, and to some extent, irreversible
process.
It
has contributed to higher investment, faster growth and rising
living standards. But this can also give rise to shocks and
stresses resulting in financial crisis as we have all witnessed in
1997 and 1998.
Testimonies
to the risks of open capital markets are the several waves of
instability in the financial markets in early 1998 and again in
the wake of the Russian crisis in August/September 1998. To
illustrate, net private capital outflows from the five countries
most affected by the crisis, namely, Indonesia, Korea, Malaysia,
Thailand and the Philippines rose to US $28.3 billion in 1998,
reflecting mainly the decline in net bank and non-bank lending.
Meanwhile, foreign direct investment which had been one of the
main sources of growth during the pre-crisis period in these
countries remained sluggish in 1998, amounting to US$8.5 billion
as compared to an average amount of US$17.8 billion during the
period 1995 to 1995.
Global
trade has experienced a slowdown over the past two years due to
trade contraction of East Asian economies. Generally, world GDP
and trade growth slowed in the past 1997/1998 as the East Asian
crisis deepened and its repercussion were felt increasingly
outside the region. Asia recorded the strongest import and export
contraction in volume and value terms of all regions of the world.
The dollar value of Asia’s imports registered an unprecedented
decline of 17.5%. The five Asian countries most affected by the
financial crisis that broke in mid-1997, that is, Malaysia,
Indonesia, Philippines, the Republic of Korea and Thailand
experienced import contraction by one-third.
In
the context of these powerful trends, I like to discuss a few
significant the issues relating to them, particularly from a
capital market regulator’s perspective. Given the breadth of the
topic at hand, and in the interest of keeping to time, please
allow me to focus particularly on current trends and difficulties
faced in the capital markets.
DEVELOPMENTS
IN ELECTRONIC COMMERCE AND CAPITAL MARKET REGULATION
Developments in computer and information technology have made
dramatic changes to the way the financial services industry
operates. These changes are affecting and will affect every aspect
of the financial services industry and offer the possibility of
reduced costs in raising capital, greater efficiencies in the
mobilisation of domestic and international savings and the
provision of better, cheaper investment products more closely
tailored to the needs of different investor segments. The
convergence of computer and communications technology is promoting
the development of computer mediated networks, allowing for users
to communicate and transmit data and other information regardless
of boundaries and distance. As communication costs continue to
fall, the potential of outsourcing grows.
These
changes will affect –
- The
way investment products are offered, distributed and marketed
and the way in which investors access information about the
products and entities involved;
- The
activities of financial services intermediaries, especially
advisers, and the way they deal with investors;
- The
continued blurring of product and institutional boundaries,
and even the scope of financial services sector itself as
non-traditional entities take on some of the functions of
financial intermediaries;
- The
methods of distribution and marketing of investment products
which will increasingly draw upon the techniques of mass
marketed consumer products; and
- The
way secondary trading in investment products takes place as
greater scope for direct investor transactions and low cost
competitors to established securities and futures markets
becomes more of a reality.
Just
as electronic commerce affects investors and providers of
financial products and services, it will affect the role of
corporations and capital market regulators. Just as electronic
commerce facilitates activities across jurisdictional borders, it
poses in clear terms questions about the practical enforceability
of national laws. As well as practical enforcement questions,
electronic commerce also raises issues about the role that capital
market regulators should play and the effectiveness of many of the
traditional regulatory approaches and mechanisms that have been
employed by them. An example might be an offering of securities
made without a prospectus or registration statement on the
Internet by a person in a jurisdiction with which the capital
market regulator has no regular contact or mutual enforcement
arrangements. There are also concerns about illegal and fraudulent
activity on the Internet.
In
this regard, the Malaysian position is that it is committed
towards a structured development of electronic commerce. Towards
this end, Malaysia has proposed to introduce a National E-Commerce
Masterplan. This Masterplan should focus on key initiatives which
will create momentum in trading via e-commerce. Besides looking at
developing the technological infrastructure such as
telecommunications infrastructure and systems providing for
electronic delivery of goods as well as payment, the Government is
also aware that there are legal and regulatory issues which will
arise with regard to e-commerce. Malaysia has introduced several
sets of laws catered towards proper regulation of e-commerce known
as ‘Cyberlaws’. The Cyberlaws which have been introduced
include, among others :
(i)
Computer Crimes Act 1997
This Act provides for a framework to counter computer offences
such as unauthorised access to computer material, crimes of fraud
and dishonesty through the computer, unauthorised modification of
contents of a computer and so on. The Act is not limited by
jurisdiction. It has effect outside as well as inside Malaysia.
Where a computer crime is committed outside Malaysia in respect of
computers or data in Malaysia or that which may be connected to or
used in Malaysia, the crime may be treated as a crime within
Malaysia and the perpetrator may be dealt with under the
provisions of this Act; and
(ii)
Digital Signatures Act 1997
This Act addresses issues of security and authenticity of
electronic transactions and it allows for greater confidentiality
and integrity of messages. It allows for businesses to use
electronic signatures instead of hand-written counterparts in
legal and business transactions. The Act provides for the
treatment of document signed with a digital signature created in
accordance with this Act to be treated as legally binding as if
the document was signed with a handwritten signature.
The
development of an effective regulatory framework is essential in
attracting and maintaining confidence for the world in trading
with Malaysian counterparts via electronic means. The regulatory
framework as it stands is currently incomplete as many other areas
such as electronic banking and broking are still in the process of
development.
To
instil confidence, Malaysia must be able to provide for regulatory
certainty and coherence as well as prevent regulatory
capriciousness. In relation to financial services, a major
consideration is cross-border implications. The Securities
Commission, as an example, is currently looking at issues relating
to Internet offering of securities and fund management and broking
services over the Internet. A re-examination of current laws would
need to be conducted to ensure that they have not been overtaken
by technology and to restructure the laws so that they are
technology neutral.
As
far as the capital market is concerned, the Securities Commission
recognises that electronic commerce is an area where it is
important that the regulatory infrastructure responds in a
positive and timely way to facilitate market developments and not
hinder innovation in market products and processes. We believe
that there are important benefits to be gained through the
Commission’s facilitation of market developments in this area
for the competitiveness of the Malaysian capital market,
efficiencies in the operation of our capital markets and the
better making of investors at lower cost. At the same time, the
Securities Commission considers that it is important for the
successful implementation of electronic commerce that investors
retain confidence in the integrity of the market for investment
products.
LIBERALISATION
VS. PROTECTIONISM
On the issue of liberalisation vis-à-vis protectionism, there has
been a proliferation of multi-lateral trade agreements since the
middle of the century. Such agreements provide for a framework of
rules within which nations are ‘obligated’ to assure other
nations signatory to the agreement of a sovereign’s approach
towards international trade. For example, Malaysia is a member of,
among others, the World Trade Organisation through which it is a
signatory to the GATS (General Agreement on Trade in Services) and
GATT (General Agreement on Tariffs in Trade), APEC as well as
ASEAN, all of which have the objective of achieving liberalised
trading of goods and services within specified, albeit not
immediate, time frames. Through these trade blocs, Malaysia has
committed itself to progressive liberalisation which essentially
entails a gradual opening of the economy to foreign participants.
The
globalisation of economies is intrinsically linked to the
internationalisation of the services industry. It plays a
fundamental role in the growing interdependence of markets and
production across nations. Information technology has further
expanded the scope of tradability of this industry. Access to
efficient services matters not only because it creates new
potential for export but also it will be an increasingly important
determinant of economic productivity and competitiveness. The main
thrusts of the ‘services revolution’ are the rapid expansion
of the knowledge-based services such as professional and technical
services, banking and insurance, healthcare and education.
Responding to this phenomenon, regulatory barriers to entry in
service industries are being reduced worldwide, either through
unilateral reforms, reciprocal negotiation or multilateral
agreements. Developing countries such as Malaysia are increasingly
looking at foreign direct investment in services as an especially
powerful means of transferring technical and managerial know-how,
besides attracting foreign capital and investment to the country.
Malaysia
has made a commitment under GATS under legal services covering
advisory and consultancy services relating to home country laws,
international law and offshore corporation laws of Malaysia. Under
the GATS commitments, commercial presence of foreign legal firms
is not available except in relation to the Federal Territory of
Labuan and in such a case, their services are limited to legal
services given to offshore corporations established in Labuan.
However, there are no limitations placed on the provision of legal
service cross-border, that is, provision of such service from a
foreigner without having a legal presence in Malaysia. This may be
done via fax, telephone or the Internet. As stated before, most
aspects of legal services does not need the physical presence of
the service provider except perhaps where a court appearance is
necessary. Furthermore, a Malaysian may obtain legal services
abroad without any limitation either.
Malaysia
is also signatory to the ASEAN Framework Agreement on Trade in
Services (AFAS). The AFAS is an agreement made within the auspices
of the GATS. In very basic terms, commitments under AFAS are
GATS-plus which means that liberalisation of trade is accelerated
within the ASEAN region under the AFAS as compared to the world at
large under GATS. Its ultimate aim is to achieve regional
integration and free flow of services within the region. In
achieving integration and free flow of services within the region,
many issues would need to be ironed out. Issues such as
harmonisation of professional standards, acceptable levels of
accreditation between member countries, movement of labour in
relation to provision of these services, licensing and
certification of service suppliers are still under intense
discussion within the Member Countries. Taking into account the
different levels of economic and regulatory maturity of Member
Countries within the ASEAN, it is understandable that it would be
a long process of consultation before a consensus may be achieved.
LIBERALISATION
OF CAPITAL ACCOUNT
A most obvious impact of globalisation of trade are pressures
exerted on developing nations to liberalise their financial
markets and capital accounts. However, it is important to
recognise that domestic and international financial liberalisation
heighten the risk of crises if not supported by prudential
supervision and regulation and appropriate macroeconomic policies.
Domestic liberalisation, by intensifying competition in the
financial sector, removes a cushion protecting intermediaries from
the consequences of bad loan and management practices. It can
allow domestic financial institutions to expand risky activities
at rates that far exceed their capacity to manage them. By
allowing domestic financial institutions access to complex
derivative instruments it can make evaluating bank balance sheets
more difficult and stretch the capacity of regulators to monitor
risks. External financial liberalisation in allowing foreign entry
into the domestic financial markets may facilitate easy access to
an abundant supply of offshore funding and risky foreign
investments. A currency crisis or unexpected devaluation (such as
in the Asian crisis) can undermine the solvency of banks and
corporations which may have built up large liabilities denominated
in foreign currency and are unprotected against foreign exchange
rate changes.
The
ideal free market is one that every one should be free to enter,
to participate in and to leave. However, events in the recent
financial crises have led many of us to believe that in the freest
of markets, there is a need to ensure that free flow of capital
does not destabilise the market itself.
Indeed,
calls for reform have gained increasing support and credence
within the international community with the unfolding of the
devastating effects of the crisis beginning mid-1997. The SC’s
work within IOSCO’s Emerging Markets Committee has drawn
attention to fundamental weaknesses in the existing global
financial infrastructure that have caused and exacerbated these
effects. These weaknesses include the inordinate power of highly
leveraged institutions to move markets, the destabilising force of
volatile short-term capital flows and the failure of existing
credit assessment systems to adequately inform market participants
of increasing risk of default.
One
example of this mounting consensus was the express recognition by
G7 countries at their recent meeting in Cologne of the need to
strengthen the international financial architecture.
There
are now increasing calls for greater transparency and regulation
of hedge funds and greater awareness of the dangers of volatile
short-term capital flows. To rebuild East Asia and the global
economy, we now urgently need to engage in a sincere discussion
about what constitutes sound governance in the contemporary world.
On
the domestic front, we would have to ask ourselves this question:
has our financial markets kept pace with change? Whilst markets
have become global, applicable rules and regulations remain
predominantly parochial or local. From a regulator’s
perspective, the challenge for us in a global market is to design
the regulatory and structural framework which will allow the
market to function efficiently, competitively in a fair and level
playing field environment, ensuring at the same time that the
market is not subject to highly concentrated or destabilising
forces that would disrupt its functioning.
The
recent crisis also shows up the need for a careful and sequenced
approach towards liberalising a country’s capital account. The
experiences of Thailand, Korea and Indonesia clearly tells us that
there is no prescribed formula on sequencing. However, it is
important to recognise that countries vary greatly in their levels
of economic and financial development, in their institutional
structures, in their legal systems and business practices, and
their capacity to manage change in a host of areas relevant for
financial liberalisation. It is in recognition of this that the
IMF policy-setting committee and subsequently the Finance
Ministers and central bank governors of the G7 industrial nations,
in the fall of 1998, stressed that a country opening its capital
account must do so in an orderly, gradual and well sequenced
manner.
Issues
of liberalisation versus protectionism would need to be considered
at great length to ensure that a country is competitive in a
global trading environment. In a developing nation such as
Malaysia, a protectionist policy towards local financial services
industry and industry participants have been adopted to assist the
local industry to develop to international standards. In the area
of financial services, for example, the Government’s stance has
been that consolidation of local financial services providers is
necessary to ensure the development of a core group of strong and
stable financial institutions to be able to withstand
international competition when the financial services markets are
opened to international participants.
Indeed,
the Malaysian experience clearly shows that a premature freeing up
of the capital account, which was done in 1988, without the
requisite reforms and institutional arrangements in order to
withstand the shocks, can result in debilitating effects as was
faced in the Malaysian financial services industry.
MALAYSIA'S
EXPERIENCE
Perhaps the most important lesson learnt from the Asian financial
crisis was the interdependence of financial markets. Even the most
developed economies were not spared of the effects of the
financial turmoil which began as a result of Thailand’s default
on its eurobond issue in February 1997. By May, 1997, the
Malaysian Ringgit was under severe pressure from currency
speculators and interest rates had risen from between 7% to 9%. It
was reported that Bank Negara Malaysia expended about RM1.2
billion of its foreign exchange reserves to try to stave off the
attack of currency speculators. However, this was the first of
many repeated attacks on the currency.
The
effects of the currency crisis began to take its toll on the
country in 1998. Interest rates were rising to above 11% and the
Ringgit had dipped to an unprecedented low of RM4.71 in January,
1998. All sectors of the economy experienced severe contraction as
access to liquidity and credit became more scarce. Bank Negara had
made many attempts to quell the effects of the financial crisis
through imposition of tight monetary policies and attempts to ease
credit to certain sectors of the economy to no avail. But the
avalanche would not stop.
Malaysia’s
sovereign credit rating was downgraded by international rating
agencies to just above so-called junk bond status. Malaysia was
facing a serious credit squeeze. Raising international capital was
prohibitively costly. Flight of capital from the country resulted
in a sharp decline in the stock market which fell to levels of 250
before bottoming out in the second half of 1998.
As
many of you are aware Malaysia’s response to the crisis was one
that was totally unexpected by the global community. The
Government decided that it needed to protect the economy from
increasing global pressures on the Malaysian economy. On 1
September, 1998 the Government introduced selective exchange
controls with the intention of curbing and preventing further
manipulation and speculation on the Ringgit. The Ringgit was
pegged at RM3.80. The Government took further measures to
discourage short-term flows of money by requiring that inflow of
funds should remain in the country for at least one year. On 15
February 1999, this was replaced with an exit levy for
repatriation of capital. The selective exchange control measures
imposed by the central bank on 1 September, 1998 were directed
towards reducing the internationalisation of the Ringgit by
eliminating access to Ringgit by speculators and reducing offshore
trading of the Ringgit. This involved the introduction of rules
relating to the external account transactions of non-residents and
currency of settlement of trade transactions. However, general
payments, including movement of funds relating to long-term
investments and repatriation of profits, interest and dividends
remain unaffected. Payment for the import of goods and services
must be made in foreign currency. All export proceeds must be
repatriated back to Malaysia within six months of the date of
export and proceeds from exports must be received in foreign
currency.
The
selective exchange control regime is intended to provide the time
and opportunity for the Government to institute the necessary
financial reforms in the Malaysian financial markets. This is in
fact in progress in the work of Danamodal (the equivalent of the
Resolution Trust Corporation of the US) to alleviate
non-performing loan from banks’ balance sheets and Danamodal
which is to recapitalise the banks. The Government is also
committed to consolidating the domestic financial services
industry in having few but strong and viable financial services
providers in order to be prepared for financial liberalisation.
GIVING
CERTAINTY TO INTERNATIONAL FINANCIAL TRANSACTIONS AND PROTECTION
TO FOREIGN INVESTMENTS
International trade and finance, because of its global nature,
necessarily involves many areas which may give rise to uncertainty
as to the applicability of the contract under which certain trade
and financing arrangements are made. These areas range from
political issues and political stability to sovereign intervention
of the economy, certainty of applicable laws as well as
independence of the judiciary.
The
Asian lawyer will be fascinated by the rapid changes which are
taking place in foreign investment law both within this region as
well as in the rest of the world. In less than half a century, the
states of Asia have moved through a whole range of stances which
could be adopted towards foreign investment. The immediate
post-colonial period was characterised by a period of hostility
towards foreign investment, motivated by the belief that the
ending of economic imperialism alone will bring about true
independence. The ensuing period was dominated by a debate about
the regulation of multinational corporations and the fear that
they posed a threat to state sovereignty. In this period, laws
were devised to control the entry of foreign investment and the
manner in which such foreign investment operated in the host
country after entry. The third and present period is a period of
pragmatism where the dominant view is that foreign investment, if
properly harnessed, can be an instrument which generates rapid
economic development. Competition for the limited investment that
is available means that each state country which is bent on a
foreign investment led growth strategy must make its laws as
hospitable to the foreign investor as the other state which is
also bent on a similar strategy.
As
much as there is competition among countries to attract foreign
investment, there is competition among multinational corporations
to enter host countries. Whereas previously the market was
dominated by large multinationals, now, there are small and medium
enterprises which can transfer more appropriate technology and
bring sufficient assets for investment.
This
“open door” policy towards foreign investment in developing
countries is typically achieved through careful screening of entry
by administrative agencies which have been established for the
purpose and regulation of the process of foreign investment after
entry has been made. After entry, there is continued surveillance
of the foreign investment to ensure that the foreign investment
keeps to the conditions upon which entry was permitted. In this
regard, attitudes to foreign investment protection and dispute
resolution will be affected by the new strategies adopted towards
foreign investment.
In
the context of the new strategies which have been developed by
controlling entry and the later surveillance of operations of
foreign investment, the foreign investment has ceased to be a
contract based matter and had become a process initiated by a
contract no doubt but controlled at every point through the public
law machinery of the state. The old notions of foreign investment
protection which concentrated on the making of the contract and
the contract as the basis of all rights of the foreign investor
would inevitably become obsolete. This transformation which has
taken place is crucial to the devising of effective methods of
foreign investment protection. The subject matter of the
protection has also changed in that not only physical assets of
the foreign investor but his intangible assets which includes
intellectual property rights as well as public law rights to
licences and privileges have become the subject of protection.
The
proposition that contractual provisions in an agreement concluded
with a host country offer little protection to foreign investment
must be qualified in a situation when a bilateral investment
treaty has been entered between the state of the foreign investor
and the host country. The result will be different, for the
contract becomes effectively internationalised as a result of the
existence of such a treaty. It is a basic proposition of
international law that any matter that is essentially within the
domestic jurisdiction of any state could be internationalised if
it is made the subject of an international treaty. The existence
of a bilateral investment treaty which covers the foreign
investment then internationalises the whole process of foreign
investment which would otherwise have been a process that takes
place entirely within the sovereign jurisdiction of the host
state. But, whether this result will follow depends on the terms
of the bilateral investment treaty.
As
a matter of general international law, the position seem to be
that a contract between a party and host country must always be
subject to a national legal system. Those who seek to prove the
contrary have an onerous task of showing that his accepted
proposition has undergone a change. There are a few usually
uncontested arbitral awards which support the view that a foreign
investment contract is subject to international law or some other
supranational system.
Bilateral
investment treaties are obviously regarded as important by both
capital exporting and capital importing states. But, these
treaties are not uniform and they do not have the ability to
create any uniform law on foreign investment protection. But their
existence adds to investor confidence and creates an expectation
of investor protection. The importance of these treaties lies in
the several results they achieve. The first is a signaling
function about the national policy towards foreign investment.
Another
advantage is that the foreign investment contract in the context
of a bilateral investment treaties could have the effect of
forming assets protected by the bilateral investment treaties.
This will also include licences and other advantages obtained from
the government during the course of the foreign investment.
Whereas without the bilateral investment treaty these licences and
advantages may have been without protection under general
international law, they new receive protection as a result of the
wide definition of property in the bilateral investment treaty.
Whether the host country did intend that its administrative
decisions be subjected to international review as a result of the
treaty, will remain a moot point. But, it remains a possible
result if the treaty.
In
Malaysia, efforts have been made by the Government to ensure a
level of certainty between international trading partners trading
with Malaysian counterparts. The Government has expressly
guaranteed that foreign companies acquiring equity participation
in local companies would not be required to restructure its equity
at any time[1]. Further to this, the Government has taken many
steps to increase confidence of foreign investors in Malaysia.
INVESTMENT
GUARANTEE AGREEMENTS (IGA”)
The Investment Guarantee Agreement protects parties involved in an
international transaction from non-commercial risks such as
nationalisation and expropriation. The IGA will provide a foreign
investor with the following :
- protection
against nationalisation and expropriation;
- prompt
and adequate compensation in the event of nationalisation or
expropriation under a lawful or public purpose;
- free
remittance of currency, profits, capital or other fees on
investment;
- settlement
of investment disputes either through a process of
consultation through diplomatic channels or if such process
fails, for referral to the International Court of Justice.
Disputes in connection with investments, under IGAs should
first be resolved through local judicial facilities. In the
event of failure to settle, it would be referred to the
Convention on the Settlement of Investment Disputes or the
International Adhoc Arbitral Tribunal established under the
Arbitration Rules of the United Nations Commission on
International Trade Law.
Malaysia
has concluded IGAs with about 64 trading nations including trading
blocs such as ASEAN and major trading partners such as the United
States of America, United Kingdom, Germany, Taiwan, etc.
TRADE
DISPUTE SETTLEMENT
Another aspect of international trade is the availability of
acceptable dispute resolution form. Globalisation of trade
obviously involves greater potential for generating international
trade disputes. The international business community looks for
prompt, economical and fair conflict-resolution mechanisms.
Negotiation, conciliation, litigation, and arbitration are
well-known conflict-resolution devices. Direct negotiations and
conciliation may resolve a conflict. However, when parties fail to
solve the controversy through direct negotiations, they have two
choices: litigation or arbitration.
Within
the context of the GATS, there is an express provision for trade
settlement dispute where countries have disputes in relation to
commitments made under the agreement. The WTO have provided for
procedures in relation to a dispute settlement process. The
dispute settlement procedure is considered to be the WTO's most
individual contribution to the stability of the global economy.
The WTO's procedure underscores the rule of law, and it makes the
trading system more secure and predictable. It is clearly
structured, with flexible timetables set for completing a case.
First rulings are made by a panel, appeals based on points of law
are possible and all final rulings or decisions are made by the
WTO's full membership. No single country can block a decision.
Malaysia
is also signatory to the Convention on the Settlement of
Investment Disputes established under the auspices of the
International Bank for Reconstruction and Development that
establishes facilities for international conciliation or
arbitration. Further to this, the Kuala Lumpur Regional Centre for
Arbitration was established in 1978 with the objective of
providing a system for the settlement of disputes for the benefit
of parties engaged in trade, commerce and investments with and
within the Asian and Pacific region.
In
conclusion, as we draw close to the new millennium, it is indeed a
challenge to us all to be able to grapple with some of the
abovementioned issues and adopt appropriate responses.
Thank you.
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You may also contact the author for any query
concerning this article : snwong@seccom.com.my
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