Implementation of Anti-Fraud Strategy for Financial Service Institutions

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FINANCIAL SERVICES AUTHORITY REGULATION
REPUBLIC OF INDONESIA
NUMBER 12 YEAR 2024
CONCERNING
THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR FINANCIAL SERVICE INSTITUTIONS

BY THE GRACE OF GOD THE ALMIGHTY,

THE COMMISSIONERS OF THE FINANCIAL SERVICES AUTHORITY,

Considering:
a. that the business activities of financial service institutions may be exposed to the risk of fraud, which causes losses to the financial services industry and/or the public; b. that to minimize the occurrence of fraud, it is necessary to strengthen the internal control system through the implementation of an anti-fraud strategy by financial service institutions;
c. that based on the considerations referred to in letters a and b, it is necessary to establish a Financial Services Authority Regulation concerning the Implementation of Anti-Fraud Strategy for Financial Service Institutions;

Recalling:

Law Number 7 of 1992 concerning Banking (State Gazette of the Republic of Indonesia Year 1992 Number 31, Supplement to the State Gazette of the Republic of Indonesia Number 3472) as amended several times, lastly with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 25 of 1992 concerning Cooperatives (State Gazette of the Republic of Indonesia Year 1992 Number 116, Supplement to the State Gazette of the Republic of Indonesia Number 3502) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 8 of 1995 concerning the Capital Market (State Gazette of the Republic of Indonesia Year 1995 Number 64, Supplement to the State Gazette of the Republic of Indonesia Number 3608) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 40 of 2004 concerning the National Insurance System (State Gazette of the Republic of Indonesia Year 2004 Number 150, Supplement to the State Gazette of the Republic of Indonesia Number 4456) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 21 of 2008 concerning Islamic Banking (State Gazette of the Republic of Indonesia Year 2008 Number 94, Supplement to the State Gazette of the Republic of Indonesia Number 4867) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 2 of 2009 concerning the Indonesian Export Financing Agency (State Gazette of the Republic of Indonesia Year 2016 Number 116, Supplement to the State Gazette of the Republic of Indonesia Number 4957) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 21 of 2011 concerning the Financial Services Authority (State Gazette of the Republic of Indonesia Year 2011 Number 111, Supplement to the State Gazette of the Republic of Indonesia Number 5253) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 24 of 2011 concerning the Social Security Administering Agency (State Gazette of the Republic of Indonesia Year 2011 Number 116, Supplement to the State Gazette of the Republic of Indonesia Number 5256) as amended with Law Number 6 of 2023 concerning the Determination of Government Regulation in Lieu of Law Number 2 of 2022 concerning Job Creation into Law (State Gazette of the Republic of Indonesia Year 2023 Number 41, Supplement to the State Gazette of the Republic of Indonesia Number 6856);
Law Number 1 of 2013 concerning Microfinance Institutions (State Gazette of the Republic of Indonesia Year 2013 Number 12, Supplement to the State Gazette of the Republic of Indonesia Number 5394) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 40 of 2014 concerning Insurance (State Gazette of the Republic of Indonesia Year 2014 Number 337, Supplement to the State Gazette of the Republic of Indonesia Number 5618) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 1 of 2016 concerning Guarantees (State Gazette of the Republic of Indonesia Year 2016 Number 9, Supplement to the State Gazette of the Republic of Indonesia Number 5835) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 4 of 2016 concerning People's Housing Savings (State Gazette of the Republic of Indonesia Year 2016 Number 55, Supplement to the State Gazette of the Republic of Indonesia Number 5863) as amended with Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);
Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (State Gazette of the Republic of Indonesia Year 2023 Number 4, Supplement to the State Gazette of the Republic of Indonesia Number 6845);

DECIDING:

To Establish: A FINANCIAL SERVICES AUTHORITY REGULATION CONCERNING THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR FINANCIAL SERVICE INSTITUTIONS.

CHAPTER I
GENERAL PROVISIONS

Article 1
In this Financial Services Authority Regulation, the following terms are defined as:

Financial Service Institution, hereinafter abbreviated as FSI, is an institution that carries out activities in the banking, capital market, insurance, pension fund, venture capital, microfinance institution, financing institution, and other financial service institutions sectors.
Other Financial Service Institutions are pawnshops, guarantee institutions, Indonesian Export Financing Agency, secondary housing financing companies, technology-based joint funding service organizers, and institutions that manage mandatory public funds, including organizers of social security, pension, and welfare programs, as referred to in legislation concerning pawnshops, guarantees, Indonesian Export Financing Agency, secondary housing financing companies, and mandatory public fund management, as well as other financial service institutions declared to be supervised by the Financial Services Authority based on legislation provisions.
Consumer is a party that places its funds and/or utilizes available services at the FSI, including customers in banking, investors in the capital market, policyholders in insurance, and participants in pension funds based on legislation provisions in the financial services sector.
Fraud is an act of deviation and/or negligence intentionally carried out to deceive, trick, or manipulate the FSI, Consumer, or other parties, occurring within the FSI environment and/or using FSI facilities, thereby causing losses to the FSI, Consumer, or other parties and/or allowing the Fraud perpetrator and/or other parties to obtain direct or indirect benefits.
Anti-Fraud Strategy is the FSI's strategy to control Fraud, designed with reference to the fraud occurrence process, considering comprehensive characteristics of potential Fraud, and implemented in the form of a Fraud control system.
Board of Directors is the FSI organ authorized and fully responsible for managing the FSI for the interests of the FSI, in accordance with the purpose and objectives of the FSI, and representing the FSI, both inside and outside the court, according to the articles of association for FSIs that are legal entities or equivalent to the Board of Directors for FSIs that are cooperative legal entities, joint ventures, pension funds, state-owned enterprises, regional-owned enterprises, regional joint-stock companies, or branches/representative offices of FSIs located abroad, or other legal entities according to legislation provisions.
Board of Commissioners is the FSI organ tasked with conducting general and/or specific supervision and providing advice to the Board of Directors according to the articles of association for FSIs that are legal entities or equivalent to the Board of Directors for FSIs that are cooperative legal entities, joint ventures, pension funds, state-owned enterprises, regional-owned enterprises, regional joint-stock companies, or branches/representative offices of FSIs located abroad, or other legal entities according to legislation provisions.

Article 2
Acts classified as Fraud consist of:
a. corruption, including:
1. conflicts of interest that harm the FSI and/or Consumer;
2. bribery;
3. illegal receipt; and/or
4. extortion;
b. asset misappropriation, including:
1. cash misappropriation;
2. inventory misappropriation; and/or
3. misappropriation of other assets;
c. financial statement fraud, including:
1. overstating net assets and/or net income; or
2. understating net assets and/or net income;
d. deception; e. leakage of confidential information; and/or f. other acts that can be equated with Fraud according to legislation provisions.

CHAPTER II
IMPLEMENTATION OF ANTI-FRAUD STRATEGY

Article 3
(1) FSIs, including:
a. commercial banks and people's economy banks, both operating conventionally and based on Sharia principles; b. securities companies; and
c. insurance companies, reinsurance companies, insurance brokers, reinsurance brokers, insurance loss appraisers, pension funds, financing companies, venture capital companies, infrastructure financing companies, microfinance institutions, pawn companies, guarantee institutions, and Other Financial Service Institutions, both operating conventionally and based on Sharia principles,
must formulate and implement an Anti-Fraud Strategy.
(2) The Board of Directors and Board of Commissioners must ensure that the implementation of the Anti-Fraud Strategy at the FSI runs effectively.
(3) The FSI ensures that controlled organizations implement the Anti-Fraud Strategy.
(4) The formulation and implementation of the Anti-Fraud Strategy as referred to in paragraph (1) must meet at least the Guidelines for the Implementation of Anti-Fraud Strategy for Financial Service Institutions as contained in Appendix I, which is an integral part of this Financial Services Authority Regulation.

Article 4
(1) In formulating and implementing an effective Anti-Fraud Strategy, the FSI must consider at least:
a. internal and external environmental conditions; b. complexity of business activities;
c. types of Fraud;
d. risks related to Fraud; and e. adequacy of required resources.
(2) The implementation of the Anti-Fraud Strategy as referred to in paragraph (1) covers prevention and handling to ensure that the FSI's business activities are not utilized in activities related to criminal acts. (3) The implementation of the Anti-Fraud Strategy must be carried out towards parties involved in the FSI's business activities, at least including:
a. Consumers; b. internal FSI; and
c. other parties.
(4) In formulating and implementing the Anti-Fraud Strategy, the FSI sets targets for the implementation of the Anti-Fraud Strategy and establishes work programs to achieve those targets.

Article 5
The formulation and implementation of the Anti-Fraud Strategy consists of 4 (four) pillars, including:
a. prevention; b. detection;
c. investigation, reporting, and sanctions; and
d. monitoring, evaluation, and follow-up.

Article 6
(1) FSIs that already have the obligation to implement risk management must apply risk management in accordance with the Financial Services Authority regulations regarding risk management implementation applicable to each FSI. (2) FSIs that do not yet have the obligation to implement risk management must apply risk management as referred to in paragraph (1) containing at least the strengthening of aspects:
a. active supervision by the Board of Directors and Board of Commissioners; b. policies and procedures;
c. organizational structure and accountability; and
d. control and monitoring, as contained in Appendix I, which is an integral part of this Financial Services Authority Regulation.

Article 7
(1) To maintain and increase understanding and concern regarding the implementation of the Anti-Fraud Strategy, the FSI must conduct education, competency development, and/or socialization of anti-Fraud policies. (2) The FSI must conduct:
a. education and competency development for internal parties; and b. education and/or socialization for external parties, regarding anti-Fraud policies, at least 1 (one) time in 1 (one) year.

Article 8
(1) The FSI must have a working unit or function tasked with handling the implementation of the Anti-Fraud Strategy within the FSI organization.
(2) The working unit or function tasked with handling the implementation of the Anti-Fraud Strategy as referred to in paragraph (1):
a. is responsible to members of the Board of Directors; and b. has direct communication and reporting relationships with the Board of Commissioners.
(3) The head of the working unit or the official overseeing the function tasked with handling the implementation of the Anti-Fraud Strategy as referred to in paragraph (1) must have:
a. expertise certificates in the field of anti-Fraud; b. experience in the field of anti-Fraud; and/or
c. adequate experience in the relevant FSI field.

Article 9
(1) FSIs, members of the Board of Directors, and/or members of the Board of Commissioners who violate the provisions as referred to in Article 3 paragraph (1), (2), (4), Article 4 paragraph (1), (3), Article 6 paragraph (2), Article 7 paragraph (1), and Article 8 paragraph (1) are subject to administrative sanctions in the form of written reprimands or written warnings by the Financial Services Authority. (2) FSIs that violate the provisions as referred to in Article 6 paragraph (1) are subject to sanctions in accordance with the Financial Services Authority regulations regarding risk management implementation applicable to each FSI. (3) In the event that the FSI has been subject to administrative sanctions as referred to in paragraph (1) and continues to violate the provisions as referred to in Article 3 paragraph (1), (4), Article 4 paragraph (1), (3), Article 6 paragraph (2), Article 7 paragraph (1), and Article 8 paragraph (1), the Financial Services Authority may impose administrative sanctions on the FSI in the form of:
a. prohibition to issue products or carry out new activities; b. temporary suspension of some operational activities;
c. restriction of business activities; and/or
d. suspension of certain business activities.
(4) In the event that members of the Board of Directors and/or members of the Board of Commissioners have been subject to administrative sanctions as referred to in paragraph (1) and continue to violate the provisions as referred to in Article 3 paragraph (2), Article 6 paragraph (2), and Article 7 paragraph (1), the Financial Services Authority may impose administrative sanctions on the members of the Board of Directors and/or members of the Board of Commissioners in the form of prohibition from acting as the principal party of the FSI in accordance with the Financial Services Authority regulations regarding re-evaluation of the principal party of the FSI. (5) In the event that, based on the Financial Services Authority's assessment, there is a significant violation requiring immediate sanctions, the imposition of sanctions as referred to in paragraph (3) and paragraph (4) may be imposed directly without preceding the imposition of sanctions as referred to in paragraph (1).

CHAPTER III
REPORTING

Article 10
(1) The FSI must submit to the Financial Services Authority:
a. the Anti-Fraud Strategy as referred to in Article 3 with reference to the Guidelines for the Implementation of Anti-Fraud Strategy for Financial Service Institutions; and b. reports or corrections of reports on the implementation of the Anti-Fraud Strategy with reference to the Guidelines for Filling Out Reports on the Implementation of Anti-Fraud Strategy. (2) In the event of a significant impact Fraud incident, the FSI must submit a report on the significant impact Fraud incident to the Financial Services Authority with reference to the Guidelines for Filling Out Reports on Significant Impact Fraud. (3) The submission of reports as referred to in paragraph (1) letter b and paragraph (2) must be carried out completely, accurately, currently, and wholly. (4) The Guidelines for Filling Out Reports on the Implementation of Anti-Fraud Strategy as referred to in paragraph (1) letter b are contained in Appendix II, which is an integral part of this Financial Services Authority Regulation. (5) The Guidelines for Filling Out Reports on Significant Impact Fraud as referred to in paragraph (2) are contained in Appendix III, which is an integral part of this Financial Services Authority Regulation.

Article 11
(1) For FSIs in the form of commercial banks, insurance companies, reinsurance companies, and financing companies, both operating conventionally and based on Sharia principles, that have obtained permits from the Financial Services Authority, the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter a must be submitted to the Financial Services Authority within a maximum period of 3 (three) months calculated from the effective date of this Financial Services Authority Regulation. (2) For FSIs in the form of people's economy banks, securities companies, insurance brokers, reinsurance brokers, insurance loss appraisers, pension funds, venture capital companies, infrastructure financing companies, microfinance institutions, pawn companies, guarantee institutions, and Other Financial Service Institutions, both operating conventionally and based on Sharia principles, that have obtained permits from the Financial Services Authority, the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter a must be submitted to the Financial Services Authority within a maximum period of 6 (six) months calculated from the effective date of this Financial Services Authority Regulation. (3) For FSIs that obtain permits after the effective date of this Financial Services Authority Regulation, the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter a must be submitted to the Financial Services Authority within a maximum period of 3 (three) months calculated from the date of obtaining the permit from the Financial Services Authority.

Article 12
In the event of changes to the Anti-Fraud Strategy that has been submitted to the Financial Services Authority as referred to in Article 11, the FSI must submit the changes to the Anti-Fraud Strategy within a maximum period of 7 (seven) working days calculated from the date the changes are made.

Article 13
Reports on the implementation of the Anti-Fraud Strategy and reports on significant impact Fraud incidents that must be submitted to the Financial Services Authority as referred to in Article 10 paragraph (1) letter b and Article 10 paragraph (2) contain at least the following information:
a. name of the FSI; b. perpetrator of the Fraud;
c. position of the perpetrator at the time of the Fraud;
d. status of follow-up handling of the Fraud; e. type of Fraud; f. activities related to the Fraud; g. description of the Fraud or modus operandi; h. location of the Fraud incident;
i. division/department where the Fraud occurred;
j. parties harmed; k. time of the Fraud incident; and
l. amount of losses.

Article 14
(1) For FSIs in the form of commercial banks and people's economy banks, both operating conventionally and based on Sharia principles, reports on the implementation of the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter b must be submitted to the Financial Services Authority every semester for the position at the end of June and the end of December, no later than on the 31st of the month following the end of the reporting month. (2) For FSIs in the form of securities companies, insurance companies, reinsurance companies, insurance brokers, reinsurance brokers, insurance loss appraisers, financing companies, pension funds, venture capital companies, infrastructure financing companies, microfinance institutions, pawn companies, guarantee institutions, and Other Financial Service Institutions, both operating conventionally and based on Sharia principles, reports on the implementation of the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter b must be submitted to the Financial Services Authority every year for the position at the end of December, no later than on January 31 of the following year.

Article 15
(1) For FSIs in the form of commercial banks, people's economy banks, securities companies, insurance companies, reinsurance companies, insurance brokers, reinsurance brokers, insurance loss appraisers, and financing companies, both operating conventionally and based on Sharia principles, reports on significant impact Fraud incidents as referred to in Article 10 paragraph (2) must be submitted to the Financial Services Authority within a maximum period of 3 (three) working days after the significant impact Fraud is known to have occurred. (2) For FSIs in the form of pension funds, venture capital companies, infrastructure financing companies, microfinance institutions, pawn companies, guarantee institutions, and Other Financial Service Institutions, both operating conventionally and based on Sharia principles, reports on significant impact Fraud incidents as referred to in Article 10 paragraph (2) must be submitted to the Financial Services Authority within a maximum period of 6 (six) working days after the significant impact Fraud is known to have occurred.

Article 16
(1) For FSIs that are:
a. conventional banks; b. people's economy banks with core capital of at least IDR 50,000,000,000.00 (fifty billion rupiah);
c. pension funds with assets of at least IDR 500,000,000,000.00 (five hundred billion rupiah); and
d. other than letters a, b, and c, with paid-up capital of more than IDR 50,000,000,000.00 (fifty billion rupiah) or with assets of more than IDR 500,000,000,000.00 (five hundred billion rupiah), whether conducting business on a conventional basis or based on Sharia principles, are required to submit the first report on the implementation of the Anti-Fraud Strategy no later than January 31, 2025. (2) For FSIs that are:
a. people's economy banks with core capital of less than IDR 50,000,000,000.00 (fifty billion rupiah); b. pension funds with assets of less than IDR 500,000,000,000.00 (five hundred billion rupiah); and
c. other than letters a and b, with paid-up capital of at most IDR 50,000,000,000.00 (fifty billion rupiah) with assets of at most IDR 500,000,000,000.00 (five hundred billion rupiah), whether conducting business on a conventional basis or based on Sharia principles, are required to submit the first report on the implementation of the Anti-Fraud Strategy no later than 1 (one) year since the implementation of this Financial Services Authority Regulation.

Article 17
(1) If the submission deadline for:
a. the Anti-Fraud Strategy as referred to in Article 11; b. changes to the Anti-Fraud Strategy as referred to in Article 12;
c. the report on the implementation of the Anti-Fraud Strategy as referred to in Article 14; and/or
d. the report on Significant Fraud Incidents as referred to in Article 15, falls on a Saturday, Sunday, and/or other public holiday, the Anti-Fraud Strategy, changes to the Anti-Fraud Strategy, the report on the implementation of the Anti-Fraud Strategy, and/or the report on Significant Fraud Incidents shall be submitted on the next working day. (2) If an FSI experiences force majeure so that it cannot submit reports until the submission deadline for documents and/or reports as referred to in paragraph (1), the FSI is required to immediately notify the Financial Services Authority in writing to obtain an extension of the submission deadline. https://jdih.ojk.go.id/

Article 18
(1) FSIs are required to correct errors or update data and/or information in the report on the implementation of the Anti-Fraud Strategy and/or the report on Significant Fraud Incidents that have been submitted to the Financial Services Authority. (2) The submission of corrections for errors or updates to data and/or information as referred to in paragraph (1) is carried out within a maximum period of 15 (fifteen) working days calculated from the discovery of errors or the knowledge of changes in data and/or information in the report on the implementation of the Anti-Fraud Strategy and/or the report on Significant Fraud Incidents. (3) Corrections for errors or updates to data and/or information as referred to in paragraph (1) are carried out based on findings by the FSI, the Financial Services Authority, and/or other competent parties.

Article 19
(1) FSIs are required to submit:
a. the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter a; b. changes to the Anti-Fraud Strategy as referred to in Article 12;
c. reports or correction reports on the implementation of the Anti-Fraud Strategy as referred to in Article 10 paragraph (1) letter b; and
d. reports on Significant Fraud Incidents as referred to in Article 10 paragraph (2), electronically through the Financial Services Authority's reporting system. (2) In the event that the Financial Services Authority's reporting system for the Anti-Fraud Strategy as referred to in paragraph (1) is not yet available at the submission deadline, FSIs submit offline via email to the Financial Services Authority, to the address of the supervisory unit responsible for each respective FSI. (3) In the event that the Financial Services Authority experiences technical difficulties at the submission deadline so that FSIs cannot submit documents and/or reports as referred to in paragraph (1), the Financial Services Authority notifies FSIs in writing about the occurrence of technical difficulties and is submitted:
a. directly to FSIs; b. through the Financial Services Authority's reporting system; and/or
c. through the Financial Services Authority's email address.
(4) FSIs are required to submit documents and/or reports as referred to in paragraph (1), within a maximum period of 1 (one) working day after the Financial Services Authority notifies that the disruption to the Financial Services Authority's reporting system has been resolved and/or the Financial Services Authority's reporting system can be used again. https://jdih.ojk.go.id/

Article 20
(1) FSIs that violate the provisions as referred to in Article 10 paragraph (1), paragraph (2), paragraph (3), Article 11, Article 12, Article 13, Article 14, Article 15, Article 16, Article 17 paragraph (2), Article 18 paragraph (1), Article 19 paragraph (1), and/or paragraph (4), are subject to administrative sanctions in the form of written reprimands or written warnings by the Financial Services Authority. (2) In addition to written reprimands or written warnings as referred to in paragraph (1), FSIs that violate the provisions as referred to in Article 11, Article 12, Article 14, Article 15, Article 16, and/or Article 18 paragraph (1) are subject to administrative sanctions in the form of fines:
a. for conventional banks, whether conducting business on a conventional basis or based on Sharia principles, in accordance with the Financial Services Authority Regulation regarding the reporting of conventional banks through the Financial Services Authority's reporting system. b. for insurance companies and reinsurance companies, whether conducting business on a conventional basis or based on Sharia principles, are subject to administrative sanctions in the form of fines of IDR 1,000,000.00 (one million rupiah) per working day of delay per report, at most IDR 30,000,000.00 (thirty million rupiah) per report.
c. for people's economy banks, securities companies, pension funds, financing companies, pawnshop companies with national business scope, guarantee institutions, insurance brokerage companies, reinsurance brokerage companies, insurance loss assessor companies, and Other Financial Service Institutions, whether conducting business on a conventional basis or based on Sharia principles, are subject to administrative sanctions in the form of fines of IDR 100,000.00 (one hundred thousand rupiah) per working day of delay per report, at most IDR 3,000,000.00 (three million rupiah) per report.
d. for venture capital companies, infrastructure financing companies, and technology-based digital financing service providers, whether conducting business on a conventional basis or based on Sharia principles, are subject to administrative sanctions in the form of fines of IDR 50,000.00 (fifty thousand rupiah) per working day of delay per report, at most IDR 1,500,000.00 (one million five hundred thousand rupiah) per report. (3) Administrative sanctions in the form of fines as referred to in paragraph (2) are exempted for pawnshop companies with District/City and/or Provincial scope and microfinance institutions. (4) FSIs that have been subject to administrative sanctions, whether in the form of written reprimands or written warnings as referred to in paragraph (1) and fines as referred to in paragraph (2), remain required to submit the Anti-Fraud Strategy or its changes, reports or correction reports on the implementation of the Anti-Fraud Strategy, and reports on Significant Fraud Incidents or their adjustments. (5) In the event that FSIs have been subject to written reprimand or written warning sanctions as referred to in paragraph (1) and/or fine sanctions as referred to in paragraph (2) and still do not fulfill the obligations as referred to in paragraph (4), the Financial Services Authority may impose administrative sanctions on FSIs in the form of:
a. prohibition to issue products or conduct new activities; b. temporary suspension of part of operational activities;
c. restriction of business activities; and/or
d. freezing of certain business activities.
(6) In the event that, based on the Financial Services Authority's assessment, there are significant violations requiring immediate sanctions, the imposition of sanctions as referred to in paragraph (5) can be directly imposed without being preceded by the imposition of sanctions as referred to in paragraph (1).

Article 21
(1) In the event that there is incorrect information submitted in reports or correction reports on the implementation of the Anti-Fraud Strategy and reports on Significant Fraud Incidents or their adjustments as referred to in Article 10 paragraph (1) letter b and Article 10 paragraph (2), FSIs are subject to administrative sanctions:
a. for FSIs that are conventional banks, whether conducting business on a conventional basis or based on Sharia principles, the imposition of administrative sanctions is carried out in accordance with the Financial Services Authority Regulation regarding the reporting of conventional banks through the Financial Services Authority's reporting system; b. for FSIs that are:
1. people's economy banks with core capital of at least IDR 50,000,000,000.00 (fifty billion rupiah);
2. pension funds with assets of at least IDR 500,000,000,000.00 (five hundred billion rupiah); and
3. other FSIs with paid-up capital of more than IDR 50,000,000,000.00 (fifty billion rupiah) or with assets of more than IDR 500,000,000,000.00 (five hundred billion rupiah),
whether conducting business on a conventional basis or based on Sharia principles, are subject to administrative sanctions in the form of fines of IDR 50,000.00 (fifty thousand rupiah) per filling error and at most IDR 5,000,000.00 (five million rupiah) per report; and
c. For FSIs that are:
1. people's economy banks with core capital of less than IDR 50,000,000,000.00 (fifty billion rupiah);
2. pension funds with assets of less than IDR 500,000,000,000.00 (five hundred billion rupiah); and
3. other FSIs with paid-up capital of at most IDR 50,000,000,000.00 (fifty billion rupiah) or with assets of at most IDR 500,000,000,000.00 (five hundred billion rupiah),
whether conducting business on a conventional basis or based on Sharia principles, are subject to administrative sanctions in the form of fines of IDR 10,000.00 (ten thousand rupiah) per filling error and at most IDR 1,000,000.00 (one million rupiah) per report. (2) Findings of incorrect information as referred to in paragraph (1) may come from FSIs, the Financial Services Authority, and/or other competent parties. (3) Administrative sanctions as referred to in paragraph (1) are exempted for:
a. updates to data and/or information for reports submitted in previous reports; and/or b. corrections for the same report and/or other reports caused by corrections to errors in data and/or information in previous reports that have been subject to administrative sanctions.

CHAPTER IV
OTHER PROVISIONS

Article 22
The accountability of FSIs for losses suffered by Consumers or other parties arising from errors and/or negligence of the Board of Directors, Board of Commissioners, employees, and/or third parties working for the benefit of FSIs is carried out in accordance with the provisions of applicable legislation.

Article 23
The Financial Services Authority may establish policies regarding the implementation of the Anti-Fraud Strategy based on considerations for specific conditions. https://jdih.ojk.go.id/

CHAPTER V
CLOSING PROVISIONS

Article 24
At the time this Financial Services Authority Regulation takes effect:
a. Financial Services Authority Regulation Number 39/POJK.03/2019 regarding the Implementation of Anti-Fraud Strategy for Conventional Banks (State Gazette of the Republic of Indonesia Year 2019 Number 246, Supplement to the State Gazette of the Republic of Indonesia Number 6439); b. Chapter XII Fraud Control and Anti-Fraud Strategy of Financial Services Authority Regulation Number 10/POJK.05/2019 regarding the Conduct of Sharia Financing Business and Sharia Business Units of Financing Companies (State Gazette of the Republic of Indonesia Year 2019 Number 40, Supplement to the State Gazette of the Republic of Indonesia Number 6320);
c. Chapter XII Fraud Control and Anti-Fraud Strategy of Financial Services Authority Regulation Number 35/POJK.05/2018 regarding the Conduct of Financing Business (State Gazette of the Republic of Indonesia Year 2018 Number 260, Supplement to the State Gazette of the Republic of Indonesia Number 6286);
d. Article 4 paragraph (3) letter e and letter f of Financial Services Authority Regulation Number 55/POJK.05/2017 regarding Periodic Reports of Insurance Companies (State Gazette of the Republic of Indonesia Year 2017 Number 174, Supplement to the State Gazette of the Republic of Indonesia Number 6107); and e. Article 72 of Financial Services Authority Regulation Number 69/POJK.05/2016 regarding the Conduct of Insurance Business, Sharia Insurance Business, Reinsurance Business, and Sharia Reinsurance Business (State Gazette of the Republic of Indonesia Year 2016 Number 302, Supplement to the State Gazette of the Republic of Indonesia Number 5992) and its implementing regulations, are revoked and declared invalid.

Article 25
This Financial Services Authority Regulation takes effect 3 (three) months after the date of enactment. https://jdih.ojk.go.id/

This copy is consistent with the original
Director of Legal Development
Legal Department
Aat Windradi

In order that everyone may know it, ordering the enactment of this Financial Services Authority Regulation by placing it in the State Gazette of the Republic of Indonesia. Established in Jakarta on July 23, 2024 CHAIRMAN OF THE BOARD OF COMMISSIONERS FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA, MAHENDRA SIREGAR

Enacted in Jakarta on July 31, 2024
MINISTER OF LAW AND HUMAN RIGHTS
REPUBLIC OF INDONESIA,
YASONNA H LAOLY
STATE GAZETTE OF THE REPUBLIC OF INDONESIA YEAR 2024 NUMBER 19/OJK ttd https://jdih.ojk.go.id/

EXPLANATION
OF
FINANCIAL SERVICES AUTHORITY REGULATION
OF THE REPUBLIC OF INDONESIA
NUMBER 12 OF 2024
REGARDING
THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR FINANCIAL SERVICE INSTITUTIONS

I. GENERAL
The increasingly complex business activities of FSIs, in line with the very rapid development of the financial services industry, result in increased risk exposure for FSIs. FSI business activities are exposed to operational risks, one of which stems from Fraud. Considering the existence of several Fraud cases in FSIs that cause losses to both the financial services industry and Consumers, and even the state, adequate support is needed to uncover Fraud incidents and actions capable of providing a deterrent effect to perpetrators. To minimize the occurrence of Fraud, various strengthening of internal control systems within FSIs is required, which simultaneously serves as support for the implementation of risk management within FSIs. Furthermore, given that Fraud incidents have the potential to cause losses to FSIs but the level of loss recovery is still low, preventive actions and continuous improvement in internal control systems through the implementation of Anti-Fraud Strategies by FSIs are highly necessary. Currently, Anti-Fraud Strategies have been operating in the conventional bank industry, the insurance industry, and the financing company industry through regulatory instruments issued by the Financial Services Authority, although there are differences in complexity in the standards regulated therein. As for the people's economy bank industry, it is still in the introduction stage of Anti-Fraud Strategies through guidelines issued by the Financial Services Authority. Meanwhile, for other industries, such as securities companies, pension funds, venture capital companies, microfinance institutions, pawnshop companies, guarantee institutions, and Other Financial Service Institutions, there have not been specific regulatory instruments requiring the aforementioned FSIs to have and implement Anti-Fraud Strategies. Therefore, provisions regarding the implementation of Anti-Fraud Strategies for conventional banks, insurance, and financing companies need to be refined in a Financial Services Authority Regulation regarding the implementation of Anti-Fraud Strategies for FSIs so that it can apply to all financial services sectors in Indonesia.

II. ARTICLE BY ARTICLE
Article 1
Sufficiently clear.

Article 2
Letter a
What is meant by "corruption" is an act with the intent to benefit a party, either individually or together with other parties, unlawfully by abusing their influence in a business transaction, or abuse of position or authority that can benefit or harm Consumers, FSIs, and/or other parties, either directly or indirectly. Number 1 Examples of conflicts of interest that harm FSIs and/or Consumers include providing lower interest rates to shareholders that do not comply with procedures and regulations, and employee acceptance based on closeness to FSI officials without considering competence. Number 2 Examples of bribery include giving bribes to third parties for permit processing. Number 3 Examples of receiving illegal benefits include receiving money, goods, and/or benefits from prospective debtors so that credit/financing requests are approved, receiving commissions, non-cash commissions for personal interests, and receiving benefits from customers outside fund management costs, service providers, prospective investment targets, or other business partners. Number 4 Examples of extortion include requesting money from Consumers/debtors to facilitate the credit/financing/FSI service process. Letter b What is meant by "asset misuse" is an act with the intent to benefit oneself and/or others unlawfully by misusing FSIs' assets and/or assets managed and/or controlled by other parties, without following the procedures applicable within the FSI and/or other parties, which causes losses or potential losses to FSIs and/or other parties. Number 1 Examples of cash misuse include theft of down payments, theft of cash registers, disbursements not matching reality, premium embezzlement, misuse of claims/guarantee funds/pension benefits. Number 2 Examples of inventory misuse include misuse and theft of assets and/or securities that have been legally recorded. Number 3 Examples of other asset misuse include using other positions as credit installment sources and utilizing other asset positions for employees' personal needs. Letter c What is meant by "financial statement fraud" is intentional misstatement or negligence in amount or disclosure in financial statements (including off-balance sheet) that do not comply with generally accepted accounting practices and are designed to benefit the perpetrator of the fraud or harm Consumers, FSIs, and/or other parties. Number 1 Examples of overstating assets and/or net income include mismatched bookkeeping times, inappropriate revenue recording, failure to disclose liabilities and expenses, mismatched asset valuation, and mismatched asset disclosure. Number 2 Examples of understating assets and/or net income include mismatched bookkeeping times, inappropriate revenue recording, overstating liabilities and expenses, mismatched asset valuation, and mismatched asset disclosure. Letter d What is meant by "fraud" is an act by a party, either individually or together with other parties, with the intent to benefit or avoid losses
unlawfully by manipulating, deceiving, providing false impressions, misleading, committing trickery or lies regarding FSIs' products and/or services, trading activities or transactions, market conditions, and/or prices, either directly or indirectly, which harm or do not harm Consumers, FSIs, and/or other parties. Examples of fraud include actions that benefit FSIs, oneself, or others unlawfully through trickery, or a series of lies such as promising certain results that Consumers will obtain but which do not match actual conditions. Letter e What is meant by "leaking confidential information" is an act with the intent to benefit a party, either individually or together with other parties, unlawfully by disseminating all information that is confidential property of FSIs and/or other parties to parties with no interest, which can benefit or harm Consumers, FSIs, and/or other parties. Examples of information leaks include providing third-party data to parties without authority and disclosing customer data and/or information and activities to unauthorized parties unless written consent has been obtained from the Customer or mandated by applicable legislation. Letter f Other actions that can be equated to Fraud that are not included in the scope of letters a through e.

Article 3
Paragraph (1)
Letter a
Sufficiently clear.
Letter b
What is meant by "securities company" is a party conducting activities as an underwriter of securities and/or securities trading intermediary or investment manager. Letter c Sufficiently clear. Paragraph (2) To ensure the implementation of Anti-Fraud Strategies in FSIs runs effectively, the Board of Directors and Board of Commissioners refer to the duties and responsibilities of the Board of Directors and Board of Commissioners. Paragraph (3) What is meant by "ensuring controlled organizations" is believing that controlled organizations, including subsidiaries and/or foundations, have policies regarding Anti-Fraud Strategies and implement them. Paragraph (4) Sufficiently clear.

Article 4
Paragraph (1)
Letter a
Internal environmental conditions include organizational structure and applicable standard procedures within FSIs. External environmental conditions include Consumer characteristics and applicable legislation. Letter b Business activity complexity is reflected in, among others: diversity in business activities, products and/or services, branch office networks or distribution channels, and/or supporting technology used. Letter c Sufficiently clear. Letter d Fraud-related risks are potential losses resulting from Fraud incidents, either directly or indirectly. Letter e Sufficiently clear. Paragraph (2) Examples of FSI business activities utilized in activities related to criminal offenses include the use of accounts for gambling activities, including online gambling, online fraud including fictitious online investment activities, online prostitution, and other economic crimes. Economic crime is a crime committed for economic motives. Paragraph (3) Letter a Sufficiently clear. Letter b Sufficiently clear. Letter c What is meant by "other parties" includes consultants, vendors, public accountants, appraisers, notaries, authorities, and governments. https://jdih.ojk.go.id/

Paragraph (4)
Clearly stated.

Article 5
Letter a
The prevention pillar contains steps to reduce the risk of Fraud occurring, including anti-Fraud awareness, identification of vulnerabilities, and employee due diligence policies, as well as other steps necessary for Fraud prevention.

Letter b
The detection pillar contains steps to identify and discover Fraud in the business activities of FSIs, including whistleblowing policies and mechanisms, surprise examinations, and supervision systems, as well as other steps necessary for Fraud detection.

Letter c
The investigation, reporting, and sanctions pillar contains steps for investigation or inquiry, reporting systems, and the imposition of sanctions against Fraud incidents in the business activities of FSIs, as well as other steps necessary for investigation, reporting, and sanctions.

Letter d
The monitoring, evaluation, and follow-up pillar contains steps to conduct monitoring, evaluation, and follow-up on Fraud, as well as other steps necessary for monitoring, evaluation, and follow-up.

Article 6
Clearly stated.

Article 7
Paragraph (1)
Education, competency development, and/or socialization of anti-Fraud policies are adjusted to the needs, size, and complexity of the FSI.

Paragraph (2)
Letter a
Education and competency development that can be provided by FSIs include, for example, procedures for implementing anti-Fraud policies, Fraud detection methodologies, and procedures for reporting Fraud incidents.

Letter b
Education and/or socialization of anti-Fraud policies that can be provided by FSIs include, for example, anti-Fraud awareness and procedures for reporting Fraud incidents.

Article 8
Paragraph (1)
The formation of a work unit or function responsible for implementing the Anti-Fraud Strategy within the FSI organization is adjusted to the size and complexity of the FSI's business activities and must be accompanied by clear authority and responsibilities.

For FSIs that already have an obligation to implement risk management, the work unit or function responsible for implementing the Anti-Fraud Strategy can be handled by the compliance and/or risk management work unit or function.

For FSIs that do not yet have an obligation to implement risk management, the work unit or function responsible for implementing the Anti-Fraud Strategy can be held concurrently by another work unit or function, provided there is hierarchical supervision (dual control) and emphasizes the principle of segregation of duties.

Paragraph (2)
Letter a
For FSIs that already have an obligation to implement risk management, the Board member who oversees the work unit or function responsible for implementing the Anti-Fraud Strategy must be a Board member who does not oversee the work unit or function responsible for operations, finance, and accounting.

For FSIs that do not yet have an obligation to implement risk management, the Board member who oversees the work unit or function responsible for implementing the Anti-Fraud Strategy can be adjusted to the size and complexity of the FSI's business activities, while still maintaining objectivity and independence.

Letter b
Clearly stated.

Paragraph (3)
Considerations for selecting the head of the work unit or official overseeing the Fraud function and the requirements to be met are adjusted to the size and complexity of the FSI's business activities.

Letter a
Clearly stated.

Letter b
Clearly stated.

Letter c
Adequate experience in the FSI field, if the official has knowledge of all business processes in the FSI and experience in various operational and non-operational fields of the FSI.

Article 9
Paragraph (1)
Clearly stated.

Paragraph (2)
Clearly stated.

Paragraph (3)
Clearly stated.

Paragraph (4)
Clearly stated.

Paragraph (5)
Significant violations based on the assessment of the Financial Services Authority include, among others, intentional violations, repeated errors, and refusal by the FSI to submit reports.

Article 10
Paragraph (1)
Clearly stated.

Paragraph (2)
Significant impact Fraud reports contain Fraud incidents estimated to have a significant negative impact on the FSI and/or Consumers, including:
a. significant violations of statutory regulations committed by the Fraud perpetrator; b. Fraud incidents that can endanger the continuity of the FSI's business; and/or
c. Fraud incidents that have the potential to attract public attention or lower the FSI's reputation.

Paragraph (3)
Clearly stated.

Paragraph (4)
Clearly stated.

Paragraph (5)
Clearly stated.

Article 11
Clearly stated.

Article 12
Clearly stated.

Article 13
Letter a
Clearly stated.

Letter b
Fraud perpetrators include internal and/or external perpetrators, both principal perpetrators and involved parties.

Letter c
Clearly stated.

Letter d
Clearly stated.

Letter e
Clearly stated.

Letter f
Clearly stated.

Letter g
Clearly stated.

Letter h
Clearly stated.

Letter i
Clearly stated.

Letter j
Clearly stated.

Letter k
Clearly stated.

Letter l
Clearly stated.

Article 14
Clearly stated.

Article 15
Clearly stated.

Article 16
Clearly stated.

Article 17
Paragraph (1)
Clearly stated.

Paragraph (2)
The term "force majeure" includes, among others, fires, floods, earthquakes, cyber attacks, and other natural or social disasters that disrupt the operational activities of the FSI, as declared or explained by the competent official or agency. The obligation of the FSI to immediately notify the Financial Services Authority in writing is intended so that the FSI notifies at the first opportunity when the situation and conditions allow.

Article 18
Paragraph (1)
Clearly stated.

Paragraph (2)
Clearly stated.

Paragraph (3)
The term "other competent parties" includes, among others, Bank Indonesia, the Deposit Insurance Corporation, the Supreme Audit Agency, the Center for Financial Transaction Reports and Analysis, Self-Regulatory Organizations, and Public Accountants.

Article 19
Clearly stated.

Article 20
Clearly stated.

Article 21
Paragraph (1)
Clearly stated.

Paragraph (2)
See the explanation of Article 18 Paragraph (3).

Paragraph (3)
Clearly stated.

Article 22
Legislation includes, among others, regulations of the Financial Services Authority regarding consumer and public protection in the financial services sector.

Article 23
Policies related to the implementation of the Anti-Fraud Strategy include, among others, the scope of FSIs and Other Financial Service Institutions, reporting deadlines and periods, as well as the scope and coverage of the Anti-Fraud Strategy policy and its implementation reports.

Considerations for specific conditions include, among others, the readiness of new financial institutions supervised by the Financial Services Authority.

Article 24
Clearly stated.

Article 25
Clearly stated.

SUPPLEMENT TO THE STATE GAZETTE OF THE REPUBLIC OF INDONESIA NUMBER 87/OJK

APPENDIX I
FINANCIAL SERVICES AUTHORITY REGULATION
NUMBER 12 YEAR 2024
CONCERNING
THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR
FINANCIAL SERVICE INSTITUTIONS

GUIDELINES FOR THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR FINANCIAL SERVICE INSTITUTIONS

I. BACKGROUND

To prevent cases of deviation in FSIs and violations of statutory regulations, particularly Fraud, which can cause losses, both directly and indirectly, to FSIs, Consumers, and/or other parties, it is necessary to improve the effectiveness of internal controls as an effort to minimize Fraud risk by implementing an Anti-Fraud Strategy.
That in order to apply good governance and risk management principles and in accordance with statutory regulations, among others, it has been regulated that Directors, Commissioners, or FSI employees who intentionally request or receive, permit or approve to receive a remuneration, commission, additional money, service, money or valuable goods, for their own benefit or for the benefit of their family, to obtain or attempt to obtain for others, constitute a type of act classified as Fraud. This also includes other actions such as giving or receiving bribes.
So far, both directly and indirectly, Fraud prevention has been implemented by FSIs, among others through the implementation of risk management, particularly internal control systems, and the implementation of good governance. However, some FSIs have not implemented Fraud prevention due to limited regulations governing anti-Fraud. For more effective implementation of the Anti-Fraud Strategy, further efforts are needed to enhance a risk-aware culture so that Fraud prevention becomes the focus of attention and concern for all levels of the FSI organization, by the Board of Directors, Board of Commissioners, and FSI employees, which is manifested, among others, by the willingness to sign integrity pacts by the Board of Directors, Board of Commissioners, and FSI employees.
The effectiveness of Fraud control in business processes is the responsibility of the Board of Directors and Board of Commissioners, so a correct and comprehensive understanding of Fraud is required by the Board of Directors and Board of Commissioners to provide direction and foster awareness for Fraud risk control in the FSI.
The Anti-Fraud Strategy is a manifestation of the commitment of the FSI's Board of Directors and Board of Commissioners in controlling Fraud, implemented in the form of a Fraud control system. This strategy requires the Board of Directors and Board of Commissioners to optimize existing resources so that the Fraud control system can be implemented effectively and continuously.
The guidelines for implementing the Anti-Fraud Strategy in these regulations direct FSIs to control Fraud through efforts not only aimed at prevention but also at detection, investigation, and system improvement as part of an integral strategy in controlling Fraud.

II. GENERAL GUIDELINES FOR IMPLEMENTING ANTI-FRAUD STRATEGY

In these guidelines, Fraud refers to intentional deviation and/or tolerance actions performed to deceive, trick, or manipulate the FSI, Consumer, or other parties, occurring within the FSI environment and/or using FSI facilities, resulting in losses to the FSI, Consumer, or other parties and/or direct or indirect benefits for the Fraud perpetrator and/or other parties. Types of acts classified as Fraud are: (i) corruption including conflicts of interest harming the FSI and/or Consumer, bribery, illegal receipt, and/or extortion; (ii) asset misuse including misuse of cash, misuse of inventory, and/or misuse of other assets; (iii) financial statement fraud including overstating or understating net assets and/or net income; (iv) deception; (v) leakage of confidential information; and/or (vi) other actions that can be equated with Fraud in accordance with statutory regulations.
Based on the approach to FSI business activities, the grouping of Fraud occurrence activities is distinguished into activities related to the main business activities of the FSI and other activities. The term "other activities" refers to FSI business activities related to other activities not related to the main business activities of the FSI.
The Anti-Fraud Strategy is the FSI's strategy in controlling Fraud, designed to develop, implement, and enhance the anti-Fraud compliance program in the FSI, referring to the Fraud occurrence process and considering the characteristics and scope of potential Fraud occurrence, compiled comprehensively, integrally, and implemented in the form of a Fraud control system. The implementation of the Anti-Fraud Strategy is part of risk management implementation, particularly related to the internal control system aspect.
The success of the Anti-Fraud Strategy is influenced by the internal and external environment conditions of the FSI that support the creation of conducive conditions so that all related parties can play an optimal role in implementing the Fraud control system in the FSI.
The complete structure of the Anti-Fraud Strategy combines basic principles of risk management, particularly internal control systems and good governance. The implementation of the Anti-Fraud Strategy in the form of a Fraud control system is elaborated through 4 (four) interrelated fraud control strategy pillars, namely: (i) prevention; (ii) detection; (iii) investigation, reporting, and sanctions; and (iv) monitoring, evaluation, and follow-up.

III. IMPLEMENTATION OF RISK MANAGEMENT
The implementation of the Anti-Fraud Strategy as part of the implementation of risk management cannot be separated from the scope of general risk management implementation. Therefore, the effectiveness of implementing the Anti-Fraud Strategy must at least be supported by strengthening the risk management aspect focusing on Fraud control. These aspects must at least include: (i) active supervision by the Board of Directors and Board of Commissioners; (ii) policies and procedures; (iii) organizational structure and accountability; and (iv) control and monitoring. The minimum scope for each supporting aspect is as follows:

Active supervision by the Board of Directors and Board of Commissioners.
Active supervision by the Board of Directors and Board of Commissioners regarding Fraud covers matters within the authority and responsibility of the Board of Directors and Board of Commissioners in implementing the Anti-Fraud Strategy in the FSI, which in its implementation refers to the duties and responsibilities of each. The authority and responsibilities must at least include:
a. developing anti-Fraud concern and culture throughout the organization, including anti-Fraud declarations and adequate communication about behaviors constituting Fraud; b. signing integrity pacts by all levels of the FSI organization, including the Board of Directors, Board of Commissioners, and every FSI employee, with the scope of the integrity pact at least containing:
1) always complying with laws and statutory regulations;
2) acting objectively, adhering to ethical and moral values, being fair, transparent, consistent, and upholding honesty and commitment;
3) playing an active role in efforts to prevent and eradicate Fraud and being willing to report in case of Fraud actions within the FSI environment; and
4) creating a work environment free from corruption, collusion, and nepotism (KKN).
c. drafting and supervising the implementation of codes of ethics related to Fraud prevention for all levels of the organization;
d. drafting and supervising the comprehensive implementation of the Anti-Fraud Strategy; e. developing human resource (HR) quality, particularly related to increasing awareness and Fraud control; f. monitoring and evaluating Fraud incidents and determining follow-up actions; and g. developing effective communication channels internally and externally for the FSI so that all officials and employees understand and comply with applicable policies and procedures, including policies and procedures for Fraud control.
Policies and procedures.
Policies and procedures drafted by the FSI for implementing Fraud control must consider the size of the FSI and the complexity of its business activities. For the implementation of policies and procedures to run effectively, these policies and procedures must be well communicated to all levels of the FSI organization and various parties related to the FSI. The policies and procedures must be designed to reduce identified risks and can prevent behaviors leading to Fraud actions. Matters to be considered in drafting and implementing Fraud prevention policies and procedures, at least:
a. commitment of the Board of Directors and Board of Commissioners; b. establishment of a comprehensive internal control system and risk assessment procedures;
c. due diligence on third parties related to the FSI;
d. determination of remuneration according to duties and responsibilities; e. application of good governance in FSI business activities; f. financial and non-financial control and application of accounting in accordance with applicable financial accounting standards; g. avoidance of conflicts of interest in decision-making, delegation of authority, and separation of functions; h. limits on the provision of gratuities according to the scope established by each FSI;
i. limits on the practice of providing/receiving facilities, gifts, and sponsorships both internally and externally;
j. mechanisms for applying the principle of knowing the beneficial owner of the FSI; k. Fraud reporting mechanisms, including whistleblowing system procedures;
l. enforcement of discipline and sanctions for violations of anti-Fraud rules;
m. periodic monitoring and evaluation of Fraud prevention policies and procedures; and n. other matters deemed necessary regarding policies and procedures.
Organizational structure and accountability.
To support the effectiveness of implementing the Anti-Fraud Strategy, the FSI has a work unit or function responsible for handling the implementation of the Anti-Fraud Strategy. Matters to be considered in forming a work unit or function responsible for handling the implementation of the Anti-Fraud Strategy, at least:
a. formation of a work unit or function in the organizational structure is adjusted to the size and complexity of the FSI's business activities. For FSIs with limited organizational structures such as microfinance institutions and non-state pawn companies, existing employees can be appointed, but in carrying out duties, they must execute a dual control mechanism known and approved by superiors and reported to the Board member overseeing the function responsible for handling the implementation of the Anti-Fraud Strategy; b. determination of clear job descriptions and responsibilities;
c. accountability of the work unit or function responsible for handling the implementation of the Anti-Fraud Strategy to the Board member;
d. establishment of direct communication and reporting relationships to the Board of Commissioners; and e. duties in the work unit or function must be carried out by HR with competence, experience in anti-Fraud and/or related FSI fields, integrity and independence, and supported by clear accountability.
Control and monitoring.
In carrying out control and monitoring, the FSI takes steps to increase the effectiveness of implementing the Anti-Fraud Strategy, at least:
a. control through review by the Board of Directors and Board of Commissioners regarding the implementation of the Anti-Fraud Strategy, as well as operational review of the implementation of the Anti-Fraud Strategy by the internal audit work unit or function or other parties appointed by the FSI; b. HR control aimed at increasing the effectiveness of task execution and Fraud control, such as rotation policies, transfer policies, mandatory leave, and social or togetherness activities;
c. determination of function separation in the implementation of FSI activities throughout the organization, adjusted to the size and complexity of the FSI's business activities, such as the application of the four eyes principle in the main business processes of the FSI to ensure that each party involved in the activity does not have the opportunity to commit and conceal Fraud in carrying out their duties; and
d. information system control supporting electronic processing, storage, and data security to prevent potential Fraud occurrence, adjusted to the size and complexity of the FSI's business activities; and e. other controls and monitoring to increase the effectiveness of implementing the Anti-Fraud Strategy, such as control, monitoring, and documentation of physical assets.

IV. ANTI-FRAUD STRATEGY
The Anti-Fraud Strategy is compiled comprehensively, integrally, and implemented in the form of a Fraud control system using devices that are an elaboration of 4 (four) interrelated pillars as follows:

Prevention.
The prevention pillar contains steps to reduce the risk of Fraud occurring, at least:
a. Anti-Fraud Awareness.
Anti-Fraud awareness is an effort to foster awareness of the importance of Fraud prevention for all levels of the FSI organization and various parties related to the FSI. Through good leadership supported by high anti-Fraud awareness, it is expected that concern for all elements in the FSI and various parties related to the FSI regarding the importance of Fraud control will grow. The morality and awareness of leadership regarding anti-Fraud must permeate every policy or regulation established. Efforts to foster anti-Fraud awareness are carried out, among others, through:
1) Drafting and socializing anti-Fraud declarations.
Socialization to internal and external parties of the FSI regarding the FSI's policies and commitment not to tolerate Fraud actions, such as policies and commitments to:
a) conduct business fairly, honestly, and openly or transparently; b) avoid doing business with third parties who are not committed in accordance with FSI policies; and/or c) provide consequences for violations of policies and commitments.
2) Anti-Fraud culture program for employees.
To encourage the application of an anti-Fraud culture for employees, the FSI can hold seminars, workshops, discussions, effective training, provide feedback, or disseminate understanding regarding policies and procedures, types of Fraud, transparency of Fraud handling processes, and follow-up on Fraud in a continuous manner. The FSI has a mechanism for giving awards to employees who have high anti-Fraud awareness and contribute to building an anti-Fraud culture.
3) Concern and vigilance program against Fraud for Consumers.
The FSI needs to increase Consumer concern and vigilance against the possibility of Fraud occurrence, among others through the creation of brochures, banners, posters, clauses, or written explanations or through other means. b. Identification of Vulnerabilities. Identification of vulnerabilities is a process to identify, analyze, and assess the risk of Fraud occurrence, which can be carried out periodically or ad hoc in case of indications of Fraud. Generally, identification of vulnerabilities is aimed at identifying the risk of Fraud occurrence inherent in every activity that has the potential to harm the FSI. The FSI conducts vulnerability identification in every activity, both sourced from internal and external information of the FSI. Identification results are not only documented and informed to all interested parties but also reviewed periodically, especially in case of activities assessed as high risk for Fraud occurrence. Some internal FSI factors that can increase the likelihood of Fraud occurrence include, among others:
1) lack of training, knowledge, and skills regarding Fraud prevention and handling;
2) culture of giving bonuses for excessive risk-taking;
3) unclear policies and procedures, among others regarding expenditure for representation, entertainment, and charitable and political donations;
4) inadequate financial control; and
5) lack of direction from the Board of Directors and Board of Commissioners regarding Fraud prevention and handling.

c. Employee Awareness Policy.
As a preventive measure against Fraud, FSIs implement an employee awareness policy, which is a human resource aspect control measure. The employee awareness policy possessed by an FSI must effectively include at least:
1) an effective recruitment or hiring system and procedure that can provide a complete and accurate picture of the candidate's background;
2) a selection system equipped with appropriate qualifications considering risk, and established objectively and transparently. This system must cover the implementation of promotions and transfers, including placement in positions with high Fraud risk; and
3) an employee awareness policy that includes, among other things, the identification and monitoring of employees' character, integrity, relationships, attitude and behavior, and lifestyle.

Detection.
The detection pillar contains steps to identify and discover Fraud in the business activities of FSIs, which must include at least:
a. Complaint Handling Policy and Mechanism (Whistleblowing).
This policy aims to increase the effectiveness of the Fraud control system implementation by focusing on disclosure through complaints. The complaint handling policy must be formulated clearly, easily understood, and effectively implementable to provide encouragement and awareness to FSI employees and/or external parties to report Fraud occurring in the FSI. In order to effectively mitigate and prevent Fraud, it is necessary to increase the effectiveness of the complaint handling policy implementation in FSIs, which must include at least:
1) Protection of Fraud reporters (whistleblowers).
FSIs must have a commitment to improve communication channels within the FSI and provide full support and protection to every Fraud reporter, guaranteeing the confidentiality of the Fraud reporter's identity as well as the implementation of examinations and disclosure of submitted reports, including the prohibition of retaliation. In this regard, reporting may be done anonymously. FSIs have a mechanism for providing reward incentives to Fraud reporters whose reports are proven true and supported by adequate evidence.
2) Regulations related to Fraud complaints.
FSIs need to formulate internal regulations regarding Fraud complaints by referring to statutory regulations.
3) Fraud reporting system and follow-up mechanism for Fraud reports.
FSIs need to formulate an effective Fraud reporting system that contains clarity of the reporting process and follow-up mechanisms for reported Fraud, in accordance with the size and complexity of the FSI's business activities, including among others, the reporting procedures, facilities, and parties responsible for handling reports. There are several ways to receive reports, including websites, electronic messaging applications, telephone, mail, email, facsimile, and other facilities. This policy is communicated transparently to all levels of the organization and to external parties of the FSI, and applied consistently to generate trust from all FSI employees and external parties regarding the reliability and confidentiality of the complaint handling mechanism. b. Surprise Audit. Surprise audit policies and mechanisms need to be carried out, especially in business units and activities that are high-risk or vulnerable to Fraud, adjusted to the size and complexity of the FSI's business activities. The implementation of surprise audits can increase employee vigilance in carrying out their duties.
c. Supervision System.
The supervision system is a testing or examination action carried out secretly without the knowledge or awareness of the tested or examined party to monitor and test the effectiveness of anti-Fraud policies. The supervision system can be carried out by independent parties and/or internal FSI parties periodically or as needed, adjusted to the size and complexity of the FSI's business activities.
Investigation, Reporting, and Sanctions.
The investigation, reporting, and sanctions pillar contains steps for investigating, reporting systems, and imposing sanctions against Fraud incidents, which must include at least:
a. Investigation.
Investigation is conducted to collect evidence related to incidents that are suspected to be Fraud actions. Investigation is an important part of the Fraud control system that sends a message to all relevant parties that every indication of detected Fraud action is always processed according to investigation standards and perpetrators are processed according to regulations. The investigation standards possessed by an FSI must include at least:
1) Determination of the party authorized to conduct investigations, considering the independence and competence required. The required competence or expertise includes:
a) analysis and investigation; b) forensic accounting; Forensic accounting is a technique for conducting detailed and comprehensive evaluation and investigation of financial and/or non-financial problems investigated using standards and rules. c) forensic computing; and/or d) fieldwork and interviews. Fieldwork is an investigation process to obtain systematic assurance through objective evidence collection. Interviews can be conducted with victims, witnesses, and suspected Fraud perpetrators to obtain complete and accurate explanations.
2) Mechanism for implementing investigations to follow up on detection results while maintaining the confidentiality of obtained information.
b. Reporting.
FSIs formulate an effective reporting mechanism for the implementation of investigations into Fraud incidents found. The reporting mechanism includes internal FSI reporting as well as reporting to the Financial Services Authority (OJK).
c. Imposition of Sanctions.
FSIs formulate an effective internal sanction imposition policy to follow up on investigation results to create a deterrent effect for Fraud perpetrators. This policy must include at least:
1) types of sanctions according to the violations committed;
2) mechanism for imposing sanctions; and
3) parties authorized to impose sanctions.
Sanction policies must be applied fairly, transparently, consistently, and provide a deterrent effect.
Monitoring, Evaluation, and Follow-up.
The monitoring, evaluation, and follow-up pillar contains steps to conduct monitoring and evaluation and follow up on Fraud, which must include at least:
a. Monitoring.
One of the important steps in implementing the Fraud control system is to monitor the follow-up actions taken regarding Fraud, both in accordance with internal FSI regulations and statutory regulations. b. Evaluation. To support the implementation of evaluation, FSIs need to maintain Fraud incident data. Fraud incident data can be used as an evaluation aid. Fraud incident data must include at least:
1) FSI name;
2) Fraud perpetrator;
3) Fraud perpetrator's position at the time of Fraud;
4) status of Fraud handling follow-up;
5) type of Fraud;
6) activity related to Fraud;
7) description of Fraud or modus operandi;
8) location of Fraud incident;
9) division/unit where Fraud occurred;
10) party harmed;
11) time of Fraud incident;
12) amount of loss;
13) cause of Fraud;
14) actions for Fraud handling; and
15) corrective actions for Fraud prevention.
Based on Fraud incident data and evaluation results, weaknesses and causes of Fraud can be identified, and handling and corrective steps required, including strengthening the internal control system, are determined. A comprehensive evaluation of the Fraud control system must be carried out periodically, and the results communicated to FSI employees.
c. Follow-up.
FSIs formulate follow-up mechanisms based on evaluation results of Fraud incidents to improve weaknesses and strengthen the internal control system to prevent the recurrence of Fraud due to similar weaknesses.

Issued in Jakarta on 23 July 2024
CHAIRMAN OF THE BOARD OF COMMISSIONERS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,
MAHENDRA SIREGAR

s/s

APPENDIX II
FINANCIAL SERVICES AUTHORITY REGULATION
NUMBER 12 OF 2024
REGARDING
THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR
FINANCIAL SERVICE INSTITUTIONS

FRAUD STRATEGY IMPLEMENTATION REPORT
PT …
FRAUD STRATEGY IMPLEMENTATION REPORT
SEMESTER ... YEAR ...

I. Development of Anti-Fraud Strategy Implementation
(Filled with a brief explanation regarding the results of evaluation and follow-up of the Anti-Fraud Strategy implementation in the reporting period).

II. Fraud Strategy Implementation Report
Fraud Incidents by Perpetrator (I)
Fraud Incident ID (II)
Type of Fraud (III)
Activity Related to Fraud (IV)
Description of Fraud / Modus Operandi (V)
Fraud Location (VI)
Division/Work Unit Where Fraud Occurred (VII)
Party Harmed (VIII)
Time (IX)
Amount of Loss (X)
Weakness Cause of Fraud (XI)
Actions for Fraud Handling (XII)
Corrective Actions for Fraud Prevention (XIII) Fraud Perpetrator Status Time Fraud Occurred Time Fraud Known Internal/External (XIV) Perpetrator Identity (XV) Perpetrator Status (XVI) Perpetrator Position (XVII) Perpetrator Description (XVIII) Sanction Imposition (XIX) Type of Fraud Description of Type of Fraud Fraud Location Description of Fraud Location Start End Actual (Incurred) Potential After Recovery Actual (Incurred) Potential After Recovery Actual (Incurred) Potential After Recovery Weakness Cause of Fraud Description Actions for Fraud Handling Description Corrective Actions for Fraud Prevention Description Target Time for Implementation Implementation Realization Name Type of Identity Identity Number Gender Identity Address Domicile Address Place of Birth Date of Birth At the Time Fraud Occurred Position Description At the Time Fraud Was Known Position Description

GUIDELINES FOR FILLING OUT THE FRAUD STRATEGY IMPLEMENTATION REPORT

I. Fraud Incidents by Perpetrator (must be filled).
Filled with 1 (one) character consisting of capital letters according to the code as follows:
Fraud Incidents by Perpetrator Code
Fraud Incident with internal perpetrator A
Fraud Incident with external perpetrator B
Fraud Incident with internal and external perpetrators C

II. Fraud Incident ID (must be filled).
Filled with 12 (twelve) characters according to the sequence of Fraud incidents.
The first digit starts with the code for fraud incidents by perpetrator, reflecting that the incident is a Fraud incident involving internal perpetrators, external perpetrators, or both internal and external perpetrators (as in Section I). Next, the 2nd digit is the reporting semester, digits 3 to 6 are the reporting year, and digits 7 to 12 are filled with numbers according to the sequence of Fraud incidents. Example:
A Fraud incident with an internal perpetrator reported in semester I of the year 2024 with sequence number 1 is written as A12024000001.
Fraud incidents with significant impact are reported again in the Fraud Strategy Implementation Report in the nearest period using the ID that was reported in the significant impact Fraud incident report.

III. Type of Fraud (must be filled).

Filled with 3 (three) characters according to the code as follows:
Type of Fraud Sub-Type of Fraud Code
Corruption Extortion 201
Conflict of interest harming
FSI and/or Consumer
Bribery 203
Unlawful receipt 204
Misappropriation of assets
Misappropriation of cash 301
Misappropriation of inventory 302
Misappropriation of other assets 303
Financial reporting fraud
Financial reporting fraud includes overstating or understating net assets and/or net income that impacts inconsistency of information with actual conditions Fraud Fraud 501 Leakage of confidential information Leakage of confidential information 601 Other actions that can be equated with Fraud Other actions that can be equated with Fraud

Examples of Fraud types occurring in FSIs, including:
a. Extortion.
Demanding money from Consumers/debtors to facilitate the credit/financing/FSI service process. b. Conflict of interest harming FSI and/or Consumer.
Providing lower interest rates to shareholders not in accordance with procedures and regulations, hiring employees based on closeness to FSI officials without considering competence.
c. Bribery.
Giving bribes to third parties for permit processing. d. Unlawful receipt.
Receiving money, goods, and/or benefits from prospective debtors so that credit/financing applications are approved, receiving commissions, discounts, non-cash commissions for personal benefit. e. Misappropriation of cash. Theft of down payments, theft of cash, disbursements not in accordance with reality, embezzlement of premiums, misappropriation of claims/guarantee funds/pension benefits, embezzlement of guarantee service fees, kafalah service fees, reinsurance service fees, and re-kafalah service fees. f. Misappropriation of inventory. Misappropriation and theft of assets not related to FSI operations. g. Misappropriation of other assets. Misappropriation and theft of assets and/or securities that have been legally recorded. h. Financial reporting fraud. Overstating net assets and/or net income, including among others, inconsistency of booking time, recording of income not in accordance, non-disclosure of liabilities and expenses, inconsistency of asset valuation, and inconsistency of asset disclosure.
i. Fraud.
Promising a specific result to be obtained by Consumers but not in accordance with actual conditions, securities trading fraud, investment management activity fraud, market manipulation, misleading information, unlicensed business activities, false and/or misleading reports and information, document forgery. j. Leakage of confidential information. Providing third-party fund data to parties without authority, disclosing data, information, and Consumer activities to unauthorized parties unless written consent has been obtained from Consumers or mandated by statutory regulations such as insider trading and abuse of authority granted by OJK regarding leakage of confidential information. k. Other actions that can be equated with Fraud. Activities harming other parties in the capital market sector, investment in affiliated parties violating laws, conducting business activities during suspension of business activities (PKU), making payments outside those regulated in pension fund regulations and statutory regulations, intentionally lending and pledging pension fund assets outside investment regulations, making cut losses not in accordance with regulations.

Description of Type of Fraud.
Must be filled if selecting "Other actions that can be equated with Fraud" in the "Type of Fraud" column (using free format).

IV. Activity Related to Fraud (must be filled).
Filled with 3 (three) characters according to the code as follows:
Activity Related to Fraud Code
Funding 301
Credit/Financing 302
Use of identity and data of others, other parties, or consumers Asset/Investment Management 304 Cyber Use 305 Bookkeeping and Financial Reporting 306 Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Counter-Proliferation Financing of Weapons of Mass Destruction (CPF-WMD) Securities Transactions 308 Marketing 309 Custody 310 Securities Allotment 311 Due Diligence in Securities Underwriting 312 Investment Research 313 Underwriting Process 314 Management of Contributions/Premiums/Contributions/Service Fees for Guarantee/Kafalah Claim/Pension Benefit Processing 316 Insurance Loss Assessment 317 Insurance/Reinsurance Selection Process 318 Underwriting Surplus Management 319 Membership Data Management 320 Subrogation Process 321 Provision of Management Services 322 Technology-Based Joint Funding Services 323 Bullion 324 Securitization 325 Market Maker 326 Activities related to digital financial assets, including crypto assets 327 Other Activities 399

Explanation of activities related to Fraud based on the type of FSI business activities is as follows:

Funding.
Fraud occurring in third-party fund collection (DPK), member savings management, and membership fund activities.
Credit/Financing.
a. Credit/financing provided by FSIs, starting from credit/financing applications to repayment by debtors/members; b. provision of financing services for securities transactions, margin transaction settlement, and/or short selling transactions;
c. provision of loans through pawn schemes;
d. distribution of loans and/or financing to housing credit financing institutions, including special tasks from the government; and e. feasibility analysis for providing credit/guarantees/financing.
Use of identity and data of others, other parties, or consumers.
Fraud occurring by using the identity and data of others, other parties, or customers to conduct transactions in the financial services sector without the knowledge and/or consent of the person, other party, or customer.
Asset/Investment Management.
Fraud occurring in the management of FSIs' financial and non-financial assets, including cash, securities, investments, tabarru funds/corporate funds/participant investment funds.
Cyber Use.
Fraud occurring using computers, computer networks, and/or electronic media to deceive FSIs, customers, persons, or other parties to obtain customer personal information and data.
Bookkeeping and Financial Reporting.
Fraud occurring in bookkeeping and/or presentation of FSIs' financial reports, including financial reports not presented in accordance with generally accepted accounting principles and/or not in accordance with actual financial conditions, including incorrect recording, such as inflating (mark up) costs and fictitious costs in bookkeeping or in FSIs' reports.
Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Counter-Proliferation Financing of Weapons of Mass Destruction (CPF-WMD).
Fraud occurring from predicate offenses referring to Financial Services Authority regulations regarding the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs in FSIs.
Securities Transactions.
Fraud occurring in the execution of buy or sell orders for securities, execution of securities transactions by securities brokers, and settlement and allocation of transactions by investment managers.
Marketing.
Fraud occurring in activities such as:
a. providing explanations to customers for opening securities accounts and investment product marketing activities; b. providing explanations to prospective policyholders, pension fund participants, insured parties, regarding activities in insurance, pension funds, and guarantee;
c. providing explanations to prospective corporate financing debtors; and
d. providing explanations to prospective Consumers regarding financial services products and services.
Custody.
Fraud occurring in the execution of custody functions.
Securities Allotment.
Fraud occurring in the execution of allotment in the public offering process.
Due Diligence in Securities Underwriting.
Fraud occurring in the due diligence process for securities underwriting.
Investment Research.
Fraud occurring in the execution of research and analysis on securities in investment portfolios that form the basis and/or will be used as investment portfolios.
Underwriting Process.
Fraud occurring in the risk analysis process to assess whether prospective insured parties can have their insurance applications accepted according to their risk level.
Management of Contributions/Premiums/Contributions/Service Fees for Guarantee/Kafalah.
Fraud occurring in the process of managing insurance premiums/contributions, reinsurance, pension fund contributions, guarantee service fees, and kafalah service fees.
Claim/Pension Benefit Processing.
Fraud occurring in the claim or pension benefit processing process when a risk event occurs for the insured party or pension benefit recipient.
Insurance Loss Assessment.
Fraud occurring in the claim assessment and/or consultation service process for insurance objects.
Insurance/Reinsurance Selection Process.
Fraud occurring in the process of selecting insurance/reinsurance parties conducted by insurance brokers/reinsurance brokers.
Underwriting Surplus Management.
Fraud occurring in the process of distributing underwriting surplus to entitled parties.
Membership Data Management.
Fraud occurring in the data recording process for participants in insurance, pension fund, and guarantee programs.
Subrogation Process.
Fraud occurring in the subrogation fund management process.
Provision of Management Services.
Fraud occurring in the provision of management services consisting of non-financial activities such as training, consulting, and business assistance.
Technology-Based Joint Funding Services.
Fraud occurring in the provision, management, and operation of financial services to match fund providers with fund recipients to conduct direct funding through electronic systems using the internet.
Bullion.
Fraud occurring in the storage, financing, trading, and safekeeping of gold activities.
Securitization.
Fraud occurring in asset transformation activities that convert illiquid assets into liquid assets through the purchase of financial assets from the original creditor and the issuance of asset-backed securities.
Market Support.
Fraud occurring in market support activities, including but not limited to the process of determining credit scores for consumers.
Activities related to digital financial assets, including crypto assets.
Fraud occurring in activities related to digital financial assets, including crypto assets, including but not limited to the execution of crypto asset buy and sell transactions.
Other Activities.
Fraud occurring in every aspect of FSI activities other than the categories grouped above (items 1 to 27).

V. Description of Fraud or Modus Operandi (must be filled).
Filled with a description of the Fraud that occurred, up to 4,000 characters (using free format), accompanied by uploading a PDF file containing the detailed description. If there is no detailed description, the PDF file must still be uploaded.

VI. Fraud Location (must be filled).

Filled with 2 (two) characters according to the location code for Fraud based on the type of conventional FSI office or Sharia FSI office as follows:

Location Code
Operational Headquarters 01
Non-Operational Headquarters 02
FSI Branch Office Located Abroad 03
Regional Office 04
Branch Office (Domestic) 05
Branch Office of an FSI Located Abroad 06
Sub-Branch Office of an FSI Located Abroad
Sub-Branch Office (Domestic) 08
Sub-Branch Office (Abroad) 09
Cash Office 10
Functional Office/Office Other Than Branch Office/Reksadana Marketing Office/Outlet/Service Unit Payment Point 12 Mobile Cash/Mobile Car/Floating Cash 13 Representative Office of an FSI Located Abroad 14 Automatic Teller Machine/Cash Deposit Machine/Cash Recycling Machine

Fraud Location Description.
Filled with 4 (four) characters according to the city/regency code listed in the Financial Information Service System (SLIK) guidelines as referred to in the Financial Services Authority regulations regarding reporting and requesting debtor information through SLIK. https://jdih.ojk.go.id/

VII. Division or Work Unit and/or Business Line Where Fraud Occurred (must be filled).
Filled with the name of the division, work unit, and/or business line where the Fraud occurred or was directly affected by the Fraud (using free format).
For Insurance Companies, this column is also filled with the division, work unit, and business line where the Fraud occurred. The business line can be filled with:

Life Insurance, namely:
a. term life; b. endowment and/or its combination;
c. whole life;
d. annuity; e. single premium life; f. personal accident; g. health; or h. others.
General Insurance:
a. property; b. motor vehicles (own damage, third party liability, and personal accident);
c. marine cargo;
d. marine hull; e. aviation hull; f. satellite; g. onshore energy (oil and gas); h. offshore energy (oil and gas);
i. engineering;
j. liability; k. personal accident;
l. health;
m. credit; n. suretyship; o. miscellaneous; or p. life.
Details regarding the division, work unit, and/or business line where the Fraud occurred must comply with insurance sector regulations.

VIII. Party Suffering Losses (must be filled).
The party suffering losses is the FSI, Consumer, and/or other parties. Filled with 3 (three) characters according to the code as follows:

Party Suffering Losses Code
FSI 001
Consumer 002
Other Parties 003

IX. Time (must be filled).

Fraud Occurred
a. Start.
Filled with the date the Fraud started (year/month/day) with the filling format YYYYMMDD. b. End.
Filled with the date the Fraud ended (year/month/day) with the filling format YYYYMMDD. https://jdih.ojk.go.id/
Fraud Discovered.
Filled with the date the Fraud was discovered by the FSI (year/month/day) with the filling format YYYYMMDD.

X. Amount of Losses (must be filled).
Filled with the numeric digits of the amount of losses incurred in full units in Rupiah currency, whether losses experienced by the FSI, Consumer, and/or other parties.

Incurred.
Filled with the amount of losses that have occurred.
Potential.
Filled with the amount of losses that may arise (potential loss).
After Recovery.
Filled with the amount of losses after there is recovery or compensation.

XI. Weaknesses Causing Fraud (must be filled).

Filled with 3 (three) characters according to the code as follows:

Weaknesses Causing Fraud Code
Human Resources – Integrity 101
Human Resources – Competence 102
Internal Control System – Management Internal Control Internal Control System – On Internal FSI Policies 202 Internal Control System – Inconsistency in Risk Levels and Tolerances Internal Control System – Violation of FSI Standards and Procedures Internal Control System – Failure of Segregation of Duties (Four Eyes Principle) Internal Control System – Inaccurate and Untimely Financial Reporting and Operational Activities Internal Control System – Ineffective Organizational Structure Information Technology 301 Ineffective Implementation of Anti-Fraud Strategy 401 External – Consumer Negligence 501 External – Consumer Understanding of Maintaining Personal Data Confidentiality External – Consumer Fraud 503 External – Other Parties' Fraud 504 Other Weaknesses 901 If there is more than one weakness causing the Fraud, it is filled in the next row with the same Fraud Incident ID.

Description of Weaknesses Causing Fraud.
Must be filled if choosing "Other Weaknesses" in the "Weaknesses Causing Fraud" column (using free format).

XII. Actions for Fraud Handling (must be filled).
Actions for fraud handling are the FSI's response to fraud incidents, whether in the form of actions against the perpetrator, the party suffering losses, or other actions. https://jdih.ojk.go.id/

Filled with 2 (two) characters according to the code as follows:

Actions for Fraud Handling Code
Issuance of warning letter 01
Rotation or transfer 02
Demotion 03
Voluntary resignation 04
Termination of employment relationship 05
Blocking debit/credit cards 06
Blocking accounts 07
Replacement of debit/credit cards 08
Police reporting or legal action 09
Compensation 10
Cancellation of policy/contract 11
Recording in track record 12
Reporting to association/regulator/agency 13
Other actions 19
If there is more than one action for fraud handling, it is filled in the next row with the same Fraud Incident ID.

Description of Actions for Fraud Handling.
Must be filled if choosing "Other Actions" in the "Actions for Fraud Handling" column (using free format).

XIII. Corrective Actions for Fraud Prevention (must be filled).

Filled with 3 (three) characters according to the code as follows:

Corrective Actions for Fraud Prevention Code
Human resources 100
Internal control system 200
Information technology 300
Implementation of Anti-Fraud Strategy 400
Coordination with association/regulator/agency 500 Other actions 900 If there is more than one corrective action for fraud prevention, it is filled in the next row with the same Fraud Incident ID.

Description of Corrective Actions for Fraud Prevention.
Filled with a description of the corrective actions taken by the FSI to prevent similar fraud incidents in the future (using free format).
Implementation Time Target.
Filled with the implementation time target for the corrective actions taken by the FSI (using free format).
Implementation Realization.
Filled with the realization of the implementation time target for the corrective actions taken by the FSI (using free format).

XIV. Internal/External (must be filled).
Filled with 3 (three) characters according to the code for the Fraud perpetrator.

Fraud Perpetrator Code
Internal 001
External 002 https://jdih.ojk.go.id/

XV. Perpetrator Identity.
For external fraud perpetrators, if the fraud perpetrator is a company, the Gender, Place of Birth, and Date of Birth columns do not need to be filled.
For external fraud perpetrators, if the fraud perpetrator is unknown, the Gender, Identity Address, Domicile Address, Place of Birth, and Date of Birth columns do not need to be filled.

Name (must be filled).
Filled with the name of the fraud perpetrator without titles as stated in the identity document.
For external fraud perpetrators, if the name of the fraud perpetrator is unknown, this column must still be filled (cannot be left blank) and the FSI defines the name of the unknown perpetrator. Example:
unknown client.
Identity Type (must be filled).
Filled with 3-digit characters according to the type of identity.

Identity Type Code Description
ID Card (National Identification Number) 001 Indonesian Fraud Perpetrator Passport (Passport Number) 002 Foreign Fraud Perpetrator Taxpayer Identification Number (NPWP) 003 Fraud Perpetrator on behalf of a company Unknown 009

Identity Number (must be filled).
Filled with the identity number according to the selected identity type.
The identity number for an unknown identity type uses a unique code created by the FSI.
If the identity number contains characters other than letters and numbers, those characters do not need to be included.
Example:
If the Fraud Perpetrator has an NPWP number 49.810.734.1-035.000, then the Identity Number column is filled with 498107341035000.
Gender.
Filled with 1 (one) character according to the code for the gender of the fraud perpetrator as follows:

Gender Code
Male L
Female P
If the fraud perpetrator is on behalf of a company or is unknown, the Gender column does not need to be filled.

Identity Address (must be filled if the fraud perpetrator is internal).
Filled with the identity address as stated in the fraud perpetrator's identity document.
Domicile Address (must be filled if the fraud perpetrator is internal).
Filled with the domicile address with information (using free format, except for city/regency, province, country which refer to the SLIK guidelines as referred to in the Financial Services Authority regulations regarding reporting and requesting debtor information through SLIK):
a. Street/block; b. House number; https://jdih.ojk.go.id/

c. RT/RW;
d. Village; e. District; f. City/Regency; g. Province; h. Country; and
i. Postal Code.

Place of Birth (must be filled if the fraud perpetrator is internal).
Filled with the place of birth of the fraud perpetrator as stated in the identity document.
Date of Birth (must be filled if the fraud perpetrator is internal).
The date of birth is filled (year/month/day) with the filling format YYYYMMDD according to the date stated in the identity document.
Example:
Date of birth December 15, 1975, written as 19751215.

XVI. Perpetrator Status (must be filled if the fraud perpetrator is internal and if the external fraud perpetrator is known).
Filled with 3 (three) characters according to the code as follows:

Status Code Description
Perpetrator
Principal
001 The Principal Perpetrator is:
a. a person who orders, instructs to do, or proposes the occurrence of an act or deed; b. a person who approves, jointly approves, or signs;
c. a person who performs or jointly performs an act based on orders from other parties, with or without pressure, and who should know or should suspect that the act or order performed is contrary to applicable regulations and does not attempt to refuse to perform the act or order; or
d. a person who performs an act due to a specific promise or reward.
Involved
Party
002 The Involved Party is a person who, in carrying out tasks, positions, and/or due to an order from other parties, with or without pressure, performs or jointly performs an act, and who should know or should suspect that the act or order performed is contrary to applicable regulations, but who has attempted to refuse to perform the act or order. https://jdih.ojk.go.id/

XVII. Perpetrator Position (must be filled if the fraud perpetrator is internal).

At the time the Fraud occurred.
a. Filled with 3 (three) characters according to the position code

Position Code Description
Principal Director/Chairman of Management
Director/Management 002
Compliance Director/Management
Compliance Field
003 The Director who oversees the compliance function.
Principal Commissioner/Chairman of Supervisory Board Commissioner/Supervisory Board Sharia Supervisory Board Executive Officer 007 An officer who is directly responsible to members of the Board of Directors or has significant influence over the policy and/or operations of the FSI. Controlling Shareholder Shareholder 009 Expert and Consultant Independent Commissioner/Independent Supervisory Board Non-Executive Officer 018 All officers other than Executive Officers. Non-Executive Employee 019 All employees other than Executive Officers and Non-Executive Officers. b. Position Description. Filled with the name of the fraud perpetrator's position at the FSI (using free format). Example:
Account Officer (AO) Credit, Group Head Credit.

At the time the Fraud was discovered.
a. Filled with 3 (three) characters according to the position code

Position Code Description
Principal Director/Chairman of Management
Director/Management 002 https://jdih.ojk.go.id/

Position Code Description
Compliance Director/Management
Compliance Field
003 The Director who oversees the compliance function.
Principal Commissioner/Chairman of Supervisory Board Commissioner/Supervisory Board Sharia Supervisory Board 006 Executive Officer 007 An officer who is directly responsible to members of the Board of Directors or has significant influence over the policy and/or operations of the FSI. Controlling Shareholder Shareholder 009 Expert and Consultant Independent Commissioner/Independent Supervisory Board Non-Executive Officer 018 All officers other than Executive Officers. Non-Executive Employee 019 All employees other than Executive Officers and Non-Executive Officers. No longer working:
Career Retirement 041
Early Retirement/Disability 042
Dismissed of one's own will
Contract/assignment expired
Deceased 045 b. Position Description (must be filled if the fraud perpetrator is internal).
Filled with the name of the fraud perpetrator's position at the FSI (using free format).
Example:
Account Officer (AO) Credit, Group Head Credit.

XVIII. Perpetrator Description (must be filled if the external fraud perpetrator is known).
Filled with 3 (three) characters according to the code as follows:

Position Code
Consumer 001
Parties working with the FSI (including vendors, investors, suppliers, state officials, or contractors) Parties not directly related to the FSI 003 https://jdih.ojk.go.id/

This copy is consistent with the original
Director of Legal Development
Legal Department
Aat Windradi

XIX. Imposition of Sanctions (must be filled).
Filled according to the actions for fraud handling in the Fraud Incident Table (using free format) according to the Fraud Incident ID involving that perpetrator.

XX. Handling Status.
Filled according to the status of fraud handling with codes as follows:

Status Code
FSI Internal Process 001
Completed FSI Internal Processing 002
In the process of handling by law enforcement agencies 003 Final and Binding (Inkracht) 004

Determined in Jakarta on July 23, 2024
CHAIRMAN OF COMMISSIONERS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,
MAHENDRA SIREGAR

APPENDIX III
FINANCIAL SERVICES AUTHORITY REGULATION
NUMBER 12 OF 2024
REGARDING
THE IMPLEMENTATION OF ANTI-FRAUD STRATEGY FOR
FINANCIAL SERVICE INSTITUTIONS https://jdih.ojk.go.id/

SIGNIFICANT IMPACT FRAUD REPORT
Fraud reported through this report is a fraud incident that has a significant impact based on the significance criteria in the guidelines for the implementation of the FSI Anti-Fraud Strategy. Fraud Incidents According to Perpetrator (I) Fraud Incident ID (II) Fraud Type (III) Fraud-Related Activities (IV) Fraud Description/Modus Operandi (V) Fraud Location (VI) Division/Work Unit Where Fraud Occurred (VII) Time (VIII) Party Suffering Losses (IX) Amount of Losses Potential (X) FSI Follow-up (XI) Fraud Perpetrator Handling Status (XVIII) Time Fraud Occurred Discovered Internal/ External (XII) Perpetrator Identity (XIII) Perpetrator Status (XIV) Perpetrator Position (XIV) Perpetrator Description (XVI) Imposition of Sanctions (XVII) Fraud Type Fraud Type Description Fraud Location Fraud Location Description Start End Name Identity Type Identity Number Gender Identity Address Domicile Address Place of Birth Date of Birth At the Time Fraud Occurred Position Description At the Time Fraud Discovered Position description 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 https://jdih.ojk.go.id/

GUIDELINES FOR FILLING OUT THE SIGNIFICANT IMPACT FRAUD REPORT
I. Fraud Incidents According to Perpetrator (must be filled).
Filled with 2 (two) characters in capital letters according to the code as follows:

Fraud Incidents According to Perpetrator Code
Fraud Incident with internal perpetrator AS
Fraud Incident with external perpetrator BS
Fraud Incident with internal and external perpetrators CS

II. Fraud Incident ID (must be filled).
Filled with 13 (thirteen) characters according to the sequence of fraud incidents.
The first digit starts with the code for the fraud incident according to the perpetrator, reflecting that the incident is a fraud incident involving an internal perpetrator, an external perpetrator, or both internal and external perpetrators (as in Section I). The 3rd digit is the reporting semester, the 4th to 7th digits are the reporting year, and the 8th to 13th digits are filled with numbers according to the sequence of fraud incidents. Example:
A fraud incident with an internal perpetrator reported in semester I of 2024 for sequence number 1 is written as AS12024000001.

III. Fraud Type (must be filled).

Filled with 3 (three) characters according to the code as follows:

Fraud Type Sub-Fraud Type Code
Corruption Extortion 201
Conflict of interest harming
FSI and/or Consumer
Bribery 203
Unlawful receipt 204
Misuse of assets
Misuse of cash 301
Misuse of supplies 302
Misuse of other assets 303
Financial reporting fraud
Financial reporting fraud includes overstating or understating net assets and/or net income which impacts inconsistency of information with actual conditions Fraud Fraud 501 Leakage of confidential information Leakage of confidential information 601 Other actions that can be equated with Fraud Other actions that can be equated with Fraud Examples of Fraud types occurring at FSIs, including:
a. Extortion.
Demanding money from Consumers/debtors to facilitate the credit/financing/FSI service process. https://jdih.ojk.go.id/

b. Conflict of interest harming the FSI and/or Consumer.
Providing lower interest rates to shareholders that do not comply with procedures and regulations, hiring employees based on closeness to FSI officials without considering competence.
c. Bribery.
Giving bribes to third parties for permit processing. d. Unlawful receipt.
Receiving money, goods, and/or benefits from prospective debtors so that credit/financing applications are approved, receiving commissions, discounts, non-cash commissions for personal benefit. e. Misuse of cash. Theft of down payments, theft of cash, withdrawals not in accordance with reality, embezzlement of premiums, misuse of claims/guarantee funds/pension benefits, embezzlement of guarantee remuneration, kafalah remuneration, reinsurance remuneration, and re-kafalah remuneration. f. Misuse of supplies. Misuse and theft of assets not related to FSI operations. g. Misuse of other assets. Misuse and theft of assets and/or securities that have been legally registered. h. Financial reporting fraud. Overstating assets and/or net income, including inconsistency in booking time, recording income that is not in accordance, not disclosing liabilities and expenses, inconsistency in asset valuation, and inconsistency in asset disclosure.
i. Fraud.
Promising a specific result to be obtained by the Consumer but not in accordance with actual conditions, securities trading fraud, investment management activity fraud, market manipulation, misleading information, unlicensed business activities, incorrect, false, and/or misleading reports and information, document forgery. j. Leakage of confidential information. Providing third-party fund data to parties without authority, disclosing consumer data, information, and activities to unauthorized parties unless written consent has been obtained from the Consumer or is required by legislation such as insider trading and misuse of authority granted by the OJK regarding leakage of confidential information. k. Other actions that can be equated with Fraud. Activities harming other parties in the capital market sector, investing in affiliated parties and violating laws, conducting business activities during business suspension (PKU), making payments outside those regulated in pension fund regulations and legislation, intentionally lending and mortgaging pension fund assets outside investment regulations, making cut losses not in accordance with regulations. https://jdih.ojk.go.id/

Description of Fraud Type.
Must be filled if choosing "Other actions that can be equated with Fraud" in the "Fraud Type" column (using free format).

IV. Fraud-Related Activities (must be filled).
Filled with 3 (three) characters according to the code as follows:

Fraud-Related Activities Code
Financing 301
Credit/Financing 302
Use of identity and data of other persons, parties, or consumers Asset/Investment Management 304 Cyber Use 305 Bookkeeping and Financial Reporting 306 Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Counter-Proliferation Financing of Weapons of Mass Destruction (CPF) Securities Transactions 308 Marketing 309 Custody 310 Securities Allotment 311 Underwriting Due Diligence 312 Investment Research 313 Underwriting Process 314 Management of Contributions/Premiums/Contributions/Remuneration for Guarantee/Kafalah Claims/Pension Benefit Processing 316 Insurance Loss Assessment 317 Insurance/Reinsurance Selection Process 318 Underwriting Surplus Management 319 Membership Data Management 320 Subrogation Process 321 Provision of Management Services 322 Technology-Based Joint Financing Services 323 Bullion 324 Securitization 325 Market Support 326 Activities related to digital financial assets, including crypto assets 327 Other Activities 399 Explanation of fraud-related activities based on the type of FSI business activities is as follows:

Financing.
Fraud occurring in the activity of gathering third-party funds (DPK), managing member savings, and membership funds.
Credit/Financing.
a. credit/financing provided by the FSI, starting from the credit/financing application to the repayment of credit/financing by the debtor/member; b. provision of financing services for securities transactions, settlement of margin transactions and/or short selling transactions; https://jdih.ojk.go.id/

c. provision of loans through pawn schemes;
d. distribution of loans and/or financing to housing credit distribution institutions, including special tasks from the government; and e. feasibility analysis for credit/guarantee/financing.

Use of identities and data of persons, other parties, or consumers.
Fraud occurring by using the identities and data of persons, other parties, or customers to conduct transactions in the financial services sector without the knowledge and/or consent of the persons, other parties, or customers.
Asset/investment management.
Fraud occurring in financial and non-financial asset management activities of FSIs, including cash, securities, investments, tabung/dana perusahaan/dana investasi peserta (savings/corporate funds/participant investment funds).
Cyber usage.
Fraud occurring using computers, computer networks, and/or electronic media to deceive FSIs, customers, persons, or other parties in order to obtain customer information and personal data.
Bookkeeping and presentation of financial reports.
Fraud occurring in bookkeeping and/or presentation of FSI financial reports, including financial reports not presented in accordance with generally accepted accounting principles and/or not in accordance with actual financial conditions, including incorrect recording, such as inflation (markup) of costs and fictitious costs in bookkeeping or in FSI reports.
Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Counter-Proliferation Financing of Weapons of Mass Destruction (CPF-WMD).
Fraud occurring from predicate offenses referring to regulations of the Financial Services Authority regarding the implementation of anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction programs in FSIs.
Securities transactions.
Fraud occurring in the execution of buy or sell orders for securities, execution of securities transactions by securities brokers, and settlement of transactions and allocations by investment managers.
Marketing.
Fraud occurring in activities such as:
a. providing explanations to customers for opening securities accounts and investment product marketing activities; b. providing explanations to prospective policyholders, pension fund participants, insured parties, regarding activities in insurance, pension funds, and guarantees;
c. providing explanations to prospective debtors of financing companies; and
d. providing explanations to prospective consumers regarding financial services products and services.
Custody.
Fraud occurring in the execution of custody functions. https://jdih.ojk.go.id/
Securities allocation.
Fraud occurring in the execution of allocation in the public offering process.
Due diligence in securities issuance underwriting.
Fraud occurring in the due diligence process in securities issuance underwriting.
Investment research.
Fraud occurring in the execution of research and analysis of securities in investment portfolios that form the basis and/or will be used as investment portfolios.
Underwriting process.
Fraud occurring in the risk analysis process to assess whether prospective insured parties can have their insurance applications accepted according to their risk level.
Management of premiums/premiums/contributions/guarantee service fees/kafalah fees.
Fraud occurring in the management process of insurance premiums/reinsurance premiums, pension fund contributions, guarantee service fees, and kafalah service fees.
Claim/pension benefit processing.
Fraud occurring in the claim or pension benefit processing process when a risk event occurs for the insured party or pension benefit recipient.
Insurance loss assessment.
Fraud occurring in the claim assessment process and/or consultation services for insurance objects.
Insurance/reinsurance selection process.
Fraud occurring in the selection process of insurance/reinsurance parties conducted by insurance brokers/reinsurance brokers.
Underwriting surplus management.
Fraud occurring in the distribution process of underwriting surplus to entitled parties.
Membership data management.
Fraud occurring in the data recording process for participants of insurance, pension funds, and guarantee programs.
Subrogation process.
Fraud occurring in the subrogation fund management process.
Management services provision.
Fraud occurring in the provision of management services consisting of non-financial activities such as training, consulting, and business assistance.
Technology-based joint financing services.
Fraud occurring in the provision, management, and operation of financial services to connect fund providers with fund recipients to conduct financing directly through electronic systems using the internet.
Bullion.
Fraud occurring in the storage, financing, trading, and consignment of gold.
Securitization.
Fraud occurring in the transformation of illiquid assets into liquid assets by purchasing financial assets from original creditors and issuing asset-backed securities. https://jdih.ojk.go.id/
Market supporters.
Fraud occurring in market support activities, including in the process of determining consumer credit scores.
Activities related to digital financial assets, including crypto assets.
Fraud occurring in activities related to digital financial assets, including crypto assets, including in the execution of crypto asset buy/sell transactions.
Other activities.
Fraud occurring in every aspect of FSI activities other than the categories grouped above (numbers 1 to 27).

V. Description of Fraud or Modus Operandi (must be filled).
Filled with a description of the fraud that occurred, up to 4,000 characters (using free format), accompanied by uploading a PDF file containing detailed descriptions. In case there are no detailed descriptions, a PDF file must still be uploaded.

VI. Fraud Location (must be filled).

Filled with 2 (two) digit characters according to the location code for Fraud based on the type of conventional FSI office or Sharia FSI office as follows:

Location Code
Operational Headquarters 01
Non-Operational Headquarters 02
Foreign-based FSI Branch Office 03
Regional Office 04
Domestic Branch Office 05
Foreign-based FSI Branch Office 06
Sub-Branch Office (Foreign) 07
Sub-Branch Office (Domestic) 08
Sub-Branch Office (Foreign) 09
Cash Office 10
Functional Office/Office other than Branch Office/Reksadana Marketing Office/Counter/Service Unit (Outlet) Payment Point 12 Mobile Cash/Mobile Car/Floating Cash 13 Foreign-based FSI Representative Office 14 Automatic Teller Machine/Cash Deposit Machine/Cash Recycling Machine

Fraud Location Description.
Filled with 4 (four) digit characters according to the city/regency code contained in the Financial Information Services System (SLIK) guidelines as referred to in Financial Services Authority regulations regarding reporting and requesting debtor information through SLIK.

VII. Division or Work Unit and/or Business Line where Fraud Occurred (must be filled).
Filled with the name of the division or work unit and/or business line where Fraud occurred or was directly affected by Fraud (using free format).
For Insurance Companies, this column is also filled with the division or work unit and business line where Fraud occurred. Business lines can be filled with:
https://jdih.ojk.go.id/

Life Insurance, namely:
a. term life; b. endowment and/or combinations thereof;
c. whole life;
d. annuity; e. single premium life; f. personal accident; g. health; or h. others.
General Insurance:
a. property; b. motor vehicles (own damage, third party liability, and personal accident);
c. marine cargo;
d. marine hull; e. aviation hull; f. satellites; g. onshore energy (oil and gas); h. offshore energy (oil and gas);
i. engineering;
j. liability; k. personal accident;
l. health;
m. credit; n. suretyship; o. miscellaneous; or p. life.
Details regarding divisions or work units and/or business lines where Fraud occurred must comply with insurance sector regulations.

VIII. Time (must be filled).

Fraud Occurred.
a. Start.
Filled with the date the Fraud started (year/month/day) with the filling format YYYYMMDD. b. End.
Filled with the date the Fraud ended (year/month/day) with the filling format YYYYMMDD.
Fraud Discovered.
Filled with the date the FSI discovered the Fraud (year/month/day) with the filling format YYYYMMDD.

IX. Affected Parties.
The affected parties are FSIs, Consumers, and/or other parties. Filled with 3 (three) digit characters according to the code as follows:

Affected Parties Code
FSI 001
Consumer 002
Other Parties 003

X. Potential Loss Amount (must be filled).
Filled with the numeric digits of the loss amount in full units with Rupiah currency. https://jdih.ojk.go.id/

XI. FSI Follow-up Actions.
Filled with an explanation of the follow-up actions taken by the FSI regarding the fraud findings (using free format, maximum 4,000 characters).

XII. Internal/External (must be filled).
Filled with 3 (three) digit characters according to the fraud perpetrator code.

Fraud Perpetrators Code
Internal 001
External 002

XIII. Perpetrator Identity.
For external fraud perpetrators, if the fraud perpetrator is a company, the Gender, Place of Birth, and Date of Birth columns do not need to be filled.
For external fraud perpetrators, if the fraud perpetrator is unknown, the Gender, Identity Address, Domicile Address, Place of Birth, and Date of Birth columns do not need to be filled.

Name (must be filled).
Filled with the name of the fraud perpetrator without titles, as stated in the identity document.
For external fraud perpetrators, if the name of the fraud perpetrator is unknown, this column must still be filled (cannot be left empty) and the FSI defines the name of the unknown perpetrator. Example:
unknown client.
Identity Type (must be filled).
Filled with 3-digit characters according to the identity type.

Identity Number (must be filled).
Filled with the identity number according to the selected identity type.
Identity numbers for unknown identity types use a unique code created by the FSI.
In case the identity number contains characters other than letters and numbers, those characters do not need to be included.
Example:
Fraud Perpetrator has NPWP number 49.810.734.1-035.000, so the Identity Number column is filled with 498107341035000.
Gender.
Filled with 1 (one) digit character according to the fraud perpetrator's gender code as follows:

Gender Code
Male L
Female P
In case the fraud perpetrator is a company or unknown, the Gender column does not need to be filled. https://jdih.ojk.go.id/

Identity Address (must be filled if fraud perpetrator is internal).
Filled with the identity address as stated in the fraud perpetrator's identity document.
Domicile Address (must be filled if fraud perpetrator is internal).
Filled with domicile address information (using free format, except for city/regency, province, country referring to SLIK guidelines as referred to in Financial Services Authority regulations regarding reporting and requesting debtor information through SLIK):
a. Street/block; b. House number;
c. RT/RW;
d. Village; e. District; f. City/Regency; g. Province; h. Country; and
i. Postal Code.
Place of Birth (must be filled if fraud perpetrator is internal).
Filled with the fraud perpetrator's place of birth as stated in the identity document.
Date of Birth (must be filled if fraud perpetrator is internal).
Date of birth is filled (year/month/day) with the filling format YYYYMMDD according to the date stated on the identity document.
Example:
Date of birth December 15, 1975, written as 19751215.

XIV. Perpetrator Status.
Filled with 3 (three) digit characters according to the code as follows:

Status Code Description
Principal
Perpetrator
001 Principal Perpetrator is:
a. a person who orders, instructs, or proposes the occurrence of an act or deed; b. a person who approves, participates in approving, or signs;
c. a person who carries out or participates in carrying out an act based on orders from other parties, with or without pressure, and who should reasonably know or reasonably suspect that the act or order carried out violates applicable regulations and does not attempt to refuse to carry out the act or order; or
d. a person who carries out an act due to specific promises or rewards.

Involved
Party
002 Involved Party is a person who, due to performing duties, positions, and/or having orders from other parties, with or without pressure, carries out or participates in carrying out an act, and who should reasonably know or reasonably suspect that the act or order carried out violates applicable regulations, but who has attempted to refuse to carry out the act or order. https://jdih.ojk.go.id/

Status Code Description menduga bahwa perbuatan atau perintah yang dilakukan tersebut bertentangan dengan ketentuan yang berlaku, namun yang bersangkutan telah berusaha untuk menolak melakukan perbuatan atau perintah tersebut.

XV. Perpetrator Position (Must be filled if Fraud Perpetrator is Internal).

At the time Fraud occurred.
a. Filled with 3 (three) digit characters according to the position code

Position Code Description
President Director/Board Chairman
Director/Board Member 002
Compliance Director/Compliance Board Member
003 Director who oversees the compliance function.
Principal Commissioner/Supervisory Board Chairman Commissioner/Supervisory Board 005 Sharia Supervisory Board 006 Executive Officer 007 Officers who are directly responsible to Board of Directors members or have significant influence on FSI policies and/or operations. Controlling Shareholder 008 Shareholder 009 Experts and Consultants 010 Independent Commissioner/Independent Supervisory Board Non-Executive Officer 018 All officers other than Executive Officers. Non-Executive Employee 019 All employees other than Executive Officers and Non-Executive Officers. b. Position Description. Filled with the fraud perpetrator's position name at the FSI (using free format). Example:
Account Officer (AO) Credit, Group Head Credit. https://jdih.ojk.go.id/

At the time Fraud was discovered.
a. Filled with 3 (three) digit characters according to the position code

Position Code Description
President Director/Board Chairman
Director/Board Member 002
Compliance Director/Compliance Board Member
003 Director who oversees the compliance function.
Principal Commissioner/Supervisory Board Chairman Commissioner/Supervisory Board 005 Sharia Supervisory Board 006 Executive Officer 007 Officers who are directly responsible to Board of Directors members or have significant influence on FSI policies and/or operations. Controlling Shareholder 008 Shareholder 009 Experts and Consultants 010 Independent Commissioner/Independent Supervisory Board Non-Executive Officer 018 All officers other than Executive Officers. No longer working:
Career retirement 041
Early retirement/disability 042
Dismissed at own request
Contract/assignment ended
Deceased 045 b. Position Description (must be filled if fraud perpetrator is internal).
Filled with the fraud perpetrator's position name at the FSI (using free format).
Example:
Account Officer (AO) Credit, Group Head Credit. https://jdih.ojk.go.id/

This copy is consistent with the original
Legal Development Director
Legal Department
Aat Windradi

XVI. Perpetrator Description (must be filled if external fraud perpetrator is known).
Filled with 3 (three) digit characters according to the code as follows:

Position Code
Consumer 001
Parties working with FSI (including vendors, investors, suppliers, state officials, or partners) Parties not directly related to FSI 003

XVII. Imposition of Sanctions.
Filled according to actions for handling Fraud in the Fraud Incident Table (using free format) according to the Fraud Incident ID involving that perpetrator.

XVIII. Handling Status.
Filled according to the fraud handling condition with codes as follows:

Status Code
FSI Internal Process 001
Completed FSI Internal Process 002
In legal enforcement agency handling process 003 Final and binding (Inkracht) 004

Determined in Jakarta on July 23, 2024
CHAIRMAN OF THE COMMISSIONERS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,
MAHENDRA SIREGAR

smd smd https://jdih.ojk.go.id/

Lineage: No known changes

Timeline

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