Based on Article 5 and Article 6 of Law (UU) No. 21 of 2011 concerning the Financial Services Authority (OJK) stipulates that OJK functions organize an integrated regulatory and supervisory system for all activities in the Financial Services Sector (FSA), namely financial services activities in the Banking sector; financial services activities in the Capital Market sector; and financial service activities in the Insurance, Pension Fund, Financing Institutions, and Other Financial Services Institutions sector, hereinafter referred to as the Non-Bank Financial Industry (IKNB).

Furthermore, Law no. 8 of 2010 concerning the Prevention and Eradication of Money Laundering and Law no. 9 of 2013 concerning the Prevention and Eradication of TPPT stipulates that the Supervisory and Regulatory Agency (LPP) is an institution that has the authority to supervise, regulate, and/or impose sanctions on the Reporting Party. In this case, OJK as the LPP of the Financial Service Providers (PJK), is mandated to stipulate the provisions of the Principles of Recognizing Service Users (PMPJ) and to supervise the compliance of the Reporting Party in implementing the PMPJ. In line with this, OJK has issued OJK Regulation (POJK) Number 12/POJK.01/2017 concerning the Implementation of Anti-Money Laundering and Prevention of Terrorism Financing Programs in the Financial Services Sector as amended by POJK No.23/POJK.01/2019, which among others regulates provisions related to PMPJ and the obligations of PJK to implement them.

​​In exercising its authority as LPP, the Supervision Work Unit at OJK in the Banking, Capital Market, and IKNB Sectors supervises the implementation of the APU PPT program for PJKs that are Reporting Parties in the APU PPT Regime. The results of the supervision of the APU PPT program are submitted by the Supervisor to the APU PPT Handling Group (GPUT) as the coordinator in the implementation of the APU PPT program implementation at OJK. Furthermore, GPUT performs data processing, analysis, and prepares recommendations on the results of the APU PPT program supervision as outlined in the Compilation and Analysis Report on Monitoring Results (LKAHP) for the APU PPT Program. The discussion on the LKAHP includes the results of the analysis of the 5 Pillars of the APU PPT program, namely Active Supervision of the Board of Directors and the Board of Commissioners; Policies and Procedures; Internal Control; Management information System; HR and Training.

Based on the results of the analysis in the LKAHP of the APU PPT Program in 2019, it is known that there are still weaknesses in the implementation of Pillar 1 of the APU PPT program, namely Active Supervision of the Board of Directors and the Board of Commissioners, including in the IKNB Sector PJK. Pillar 1 is the main foundation in optimizing the implementation of the APU PPT program in PJK (tone of the top). The active supervision of the Board of Directors and the Board of Commissioners will greatly influence the implementation of the APU PPT program on other pillars so that PJKs that have weaknesses in these aspects need special attention.

PJK compliance with the implementation of the AML-CFT program will make the AML-CFT regime in Indonesia stronger because it can protect PJK from vulnerabilities in Money Laundering (TPPU) and Terrorism Prevention Crimes. The strengthening of the implementation of the APU PPT program for the Board of Directors and the Board of Commissioners of PJK will also have an impact on stricter monitoring from the highest leadership of PJK to create a higher level of compliance than PJK.

Furthermore, higher compliance from PJK can directly have a positive influence on the role of OJK as the largest LPP which in turn can improve Indonesia’s APU PPT Regime in terms of prevention. This is also related to the Mutual Evaluation Review (MER) assessment process for Indonesia’s membership in the Financial Action Task Force (FATF) where equality in the implementation of the APU PPT program is needed because Indonesia is aligned with FATF member countries that have been qualified in implementing the APU PPT program.

In connection with the above matters, to increase the understanding and awareness of the Board of Directors and the Board of Commissioners in the application of the AML/CFT program as well as an effort to prevent the occurrence of ML/TPPT in the Financial Services Sector, it is necessary to carry out capacity building (in the form of sharing sessions). Which is devoted to the Board of Directors and Board of Commissioners of the NBFI Sector regarding the importance of implementing the APU PPT program. The sharing session is designed so that the top-level management of the PJK IKNB Sector can get a complete picture regarding the importance of implementing the APU PPT program, the obligations that must be carried out, and best practices related to the implementation of the APU PPT program. An explanation regarding the importance of implementing the APU PPT program is planned to be given from the leadership level as a tone of the top support from the government side and to provide a strong message for PJK.

The purpose of this sharing session is to increase the understanding and awareness of the Board of Directors and the Board of Commissioners of the importance of the APU PPT program as well as strengthen supervision over the implementation of the AML and CFT program carried out by the Board of Directors and the Board of Commissioners themselves so that they can be applied directly to the Financial Services Industry they lead.