Implementation of Compliance Functions for Rural Banks and Sharia Rural Banks

To:
Directors of Rural Banks (BPR) and Sharia Rural Banks (BPR Syariah) At Location.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 8/SEOJK.03/2025

CONCERNING

THE IMPLEMENTATION OF COMPLIANCE FUNCTIONS FOR RURAL BANKS (BPR) AND SHARIA RURAL BANKS (BPR SYARIAH)

In light of the promulgation of the Financial Services Authority Regulation Number 9 of 2024 concerning the Implementation of Governance for Rural Banks (BPR) and Sharia Rural Banks (BPR Syariah) (State Gazette of the Republic of Indonesia Year 2024 Number 13/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 81/OJK), hereinafter referred to as the POJK on the Implementation of BPR and BPR Syariah Governance, as well as the Financial Services Authority Regulation Number 25 of 2024 concerning the Implementation of Sharia Governance for Sharia Rural Banks (BPR Syariah) (State Gazette of the Republic of Indonesia Year 2024 Number 35/OJK, Supplement to the State Gazette of the Republic of Indonesia Number 103/OJK), hereinafter referred to as the POJK on the Implementation of Sharia Governance for BPR Syariah, it is necessary to regulate implementation provisions regarding the implementation of compliance functions for BPR and BPR Syariah in this Financial Services Authority Circular as follows:

I. GENERAL PROVISIONS

1. The compliance function is a function that carries out a series of preventive (ex-ante) actions or steps to ensure that policies, regulations, systems, procedures, and business activities conducted by BPR and BPR Syariah are in accordance with statutory regulations, including Sharia Principles for BPR Syariah, and to ensure BPR and BPR Syariah's compliance with commitments made to the Financial Services Authority and other authorities. The compliance function is independent of business operations.

2. The compliance function for BPR Syariah includes the Sharia compliance function as regulated in the POJK on the Implementation of Sharia Governance for BPR Syariah.

3. In compliance risk assessment, the process of identifying, measuring, monitoring, and controlling compliance risks at BPR and BPR Syariah is conducted by the risk management organization involving the compliance function organization. Compliance risk is in accordance with the Financial Services Authority Regulations regarding the implementation of risk management for rural credit institutions and the Financial Services Authority Regulations regarding the implementation of risk management for Sharia rural financing institutions.

4. In accordance with Article 3 paragraph (1) of the POJK on the Implementation of BPR and BPR Syariah Governance, BPR and BPR Syariah are required to have internal procedures regarding the implementation of Good Governance at BPR and BPR Syariah in the conduct of business activities. Internal procedures that must be possessed by BPR and BPR Syariah include guidelines for the implementation of the compliance function.

Guidelines for the implementation of the compliance function for BPR and BPR Syariah as regulated in this Financial Services Authority Circular are standard minimum references that must be fulfilled by BPR and BPR Syariah in order to realize one aspect of governance implementation.

BPR and BPR Syariah formulate and develop guidelines for the implementation of the compliance function in accordance with the needs and complexity of business operations, strategies, and the vision and mission of each BPR and BPR Syariah, with reference to the guidelines for the implementation of the compliance function as contained in Appendix I, which is an integral part of this Financial Services Authority Circular.

II. IMPLEMENTATION OF THE COMPLIANCE FUNCTION AT BPR AND BPR SYARIAH

1. All Directors are responsible for fostering and realizing the implementation of a compliance culture by applying integrity values at all levels of the BPR and BPR Syariah organization and business activities. A compliance culture is values, behavior, and actions that support the creation of compliance with Financial Services Authority regulations and other statutory regulations, including Sharia Principles for BPR Syariah.

2. All individuals at BPR and BPR Syariah carry out their duties in accordance with statutory regulations, including Sharia Principles for BPR Syariah, and ethical values, standards, principles, and practices stipulated in the internal policies and procedures of BPR and BPR Syariah, including guidelines, codes of conduct, or charters.

3. To ensure BPR and BPR Syariah's compliance with Financial Services Authority regulations and other statutory regulations, including Sharia Principles for BPR Syariah, BPR and BPR Syariah must have a Director who oversees the compliance function and an organization for the compliance function.

4. In accordance with Article 44 paragraph (6) letter a of the POJK on the Implementation of BPR and BPR Syariah Governance, the Board of Commissioners conducts supervision over the implementation of the compliance function at BPR and BPR Syariah. Supervision is conducted actively by:
   a. evaluating the implementation of the compliance function periodically, including through discussions in Board of Commissioners meetings; b. providing suggestions and directions to the Board of Directors to improve the quality of compliance function implementation;
   c. ensuring the Board of Directors follows up on supervision results regarding the implementation of the compliance function, including the fulfillment of commitments to authorities; and
   d. conducting discussions with the Board of Directors and/or the Sharia Supervisory Board (DPS) regarding the latest and relevant Financial Services Authority regulations or other statutory regulations, including Sharia Principles for BPR Syariah, including through discussions in meetings between the Board of Commissioners and the Board of Directors and/or meetings of the DPS together with the Board of Commissioners.

The Board of Commissioners must properly administer all documents regarding supervision of the implementation of the compliance function.

The Board of Directors' follow-up on supervision results regarding the implementation of the compliance function becomes part of the main report on the duties of the Director overseeing the compliance function, accompanied by information on the Board of Commissioners' supervision results regarding the implementation of the compliance function at BPR and BPR Syariah.

5. For BPR Syariah, the Director overseeing the compliance function, the compliance work unit, and the Executive Officer implementing the compliance function must coordinate with the DPS regarding the implementation of the compliance function concerning Sharia Principles.

III. DIRECTOR OVERSEEING THE COMPLIANCE FUNCTION

1. In accordance with Article 73 paragraph (1) of the POJK on the Implementation of BPR and BPR Syariah Governance, the Director overseeing the compliance function at BPR and BPR Syariah with core capital of at least IDR 50,000,000,000.00 (fifty billion rupiah) must be independent, meaning they do not handle fund disbursement, fund collection, procurement of goods and services, and other operational activities.

Example:
The Board of Directors of PT BPR VWX consists of 1 (one) President Director, 1 (one) Operational Director, and 1 (one) Director overseeing the compliance function. The Director overseeing the compliance function may handle non-operational activities such as the human resources division, but must not make decisions or approvals regarding the procurement of labor or human resource development services. Decisions or approvals regarding the procurement of labor or human resource development services are made by the President Director.

2. In accordance with Article 73 paragraph (2) letter a of the POJK on the Implementation of BPR and BPR Syariah Governance, the Director overseeing the compliance function at BPR and BPR Syariah with core capital of less than IDR 50,000,000,000.00 (fifty billion rupiah) must not be involved in operational decision-making regarding fund disbursement, fund collection, procurement of goods and services, and other operational activities.

Example:
The Board of Directors of PT BPR XYZ consists of 1 (one) President Director and 1 (one) Director overseeing the compliance function. The Director overseeing the compliance function may handle the administration and legal credit division, while credit decisions are made by the President Director who handles the credit division.

The execution of duties by the Director of PT BPR XYZ overseeing the compliance function in administrative and legal credit activities must be carried out as part of the control to fulfill credit disbursement requirements.

3. Other operational activities as referred to in items 1 and 2 are activities or operations directly related to business responsibilities and can pose risk exposure to BPR and BPR Syariah. The Director overseeing the compliance function may still assist other Directors, provided that the segregation of duties is ensured by performing checks and balances or counterweights against business decisions taken by BPR or BPR Syariah, such as ensuring the fulfillment of all internal regulations and guidelines during the analysis process up to approval.

4. In accordance with Article 73 paragraph (1) and paragraph (2) letter b of the POJK on the Implementation of BPR and BPR Syariah Governance, the Director overseeing the compliance function must have competencies related to the implementation of compliance duties, including understanding:
   a. Financial Services Authority Regulations and their implementing regulations; b. other authority regulations, such as Bank Indonesia regulations and Deposit Insurance Agency regulations;
   c. other statutory regulations, such as tax regulations; and
   d. Sharia Principles for BPR Syariah, which are related to banking, particularly BPR or BPR Syariah.

5. The Director overseeing the compliance function has duties and responsibilities as specified in Appendix I, which is an integral part of this Financial Services Authority Circular.

6. In accordance with Article 74 paragraph (2) of the POJK on the Implementation of BPR and BPR Syariah Governance, if the Director overseeing the compliance function is permanently unable to serve, resigns, or their term of office expires, BPR and BPR Syariah are required to appoint a replacement for the Director overseeing the compliance function.

The definition of permanently unable to serve includes:
a. death; b. mental disability or other conditions that prevent the individual from performing duties as a Director;
c. violation of regulations regarding:

1. prohibitions for Directors to hold concurrent positions and/or family relationships; and/or
2. requirements for holding work competency certificates;
   d. being determined as "Fail" in the re-evaluation process in accordance with Financial Services Authority Regulations regarding the re-evaluation of key parties of financial service institutions; and/or e. exceeding the temporary inability period as regulated in the BPR and BPR Syariah compliance work guidelines, systems, and procedures.

7. The definition of temporary inability includes conditions that cause the Director to be unable to perform their duties for a certain period, including leave, illness, official travel, and/or undergoing legal processes.

IV. COMPLIANCE WORK UNIT AND EXECUTIVE OFFICER IMPLEMENTING THE COMPLIANCE FUNCTION

1. In accordance with Article 72 paragraph (3) of the POJK on Governance for BPR and BPR Syariah, BPR and BPR Syariah with core capital of at least IDR 50,000,000,000.00 (fifty billion rupiah) are required to form an independent compliance work unit separate from operational work units, namely units conducting fund disbursement, fund collection, procurement of goods and services, and other operational activities.

Example:
The Head of the compliance work unit may concurrently serve as an Executive Officer handling the legal field.

2. In accordance with Article 72 paragraph (4) of the POJK on Governance for BPR and BPR Syariah, BPR and BPR Syariah with core capital of less than IDR 50,000,000,000.00 (fifty billion rupiah) are required to assign an Executive Officer to implement the compliance function and not handle matters related to operational decision-making in fund disbursement, fund collection, procurement of goods and services, and other operational activities.

Example:
The Executive Officer implementing the compliance function may handle credit or financing administration and legal processes, while credit or financing decisions are made by the President Director handling the credit or financing division.

3. In accordance with Article 22 paragraph (2) and paragraph (3) of the POJK on BPR and BPR Syariah Governance:
   a. the compliance work unit and risk management work unit may be merged into 1 (one) unit handling compliance and risk management; and b. the Executive Officer implementing the compliance function may concurrently serve as the Executive Officer assigned to implement the risk management function.

4. The compliance work unit and Executive Officer implementing the compliance function may also perform non-operational and non-business functions, namely anti-money laundering, counter-terrorism financing, and counter-proliferation financing of weapons of mass destruction (APU, PPT, and PPPSPM).

5. The merger or concurrent holding of functions as referred to in items 3 and 4 may be conducted if BPR and BPR Syariah can ensure the effectiveness of the execution of duties and responsibilities of each function.

6. In accordance with Article 22 paragraph (5) of the POJK on BPR and BPR Syariah Governance, the Financial Services Authority has the authority to order BPR and BPR Syariah with core capital of less than IDR 50,000,000,000.00 (fifty billion rupiah) to increase the number of human resources implementing the compliance function, considering:
   a. the Financial Services Authority's assessment results of governance implementation reports, including the main report on the duties of the Director overseeing the compliance function; b. the Financial Services Authority's evaluation results of compliance risk assessments, such as the type, significance, and frequency of violations, as well as success in resolving violations; and/or
   c. the business activities of BPR and BPR Syariah, including the diversity and complexity of products and activities, as well as the number and distribution of office networks.

7. The compliance work unit or Executive Officer implementing the compliance function has duties and responsibilities as specified in Appendix I, which is an integral part of this Financial Services Authority Circular.

8. In accordance with Article 72 paragraph (6) of the POJK on Governance for BPR and BPR Syariah, the compliance work unit and Executive Officer implementing the compliance function are required to formulate and/or establish compliance work guidelines, systems, and procedures. Compliance work guidelines, systems, and procedures are formulated by the compliance work unit or Executive Officer implementing the compliance function and approved by the Director overseeing the compliance function, with content including at least:
   a. the party responsible for implementing the compliance function, including if the Director overseeing the compliance function is permanently or temporarily unable to serve, considering Financial Services Authority regulations governing the implementation of governance for BPR and BPR Syariah. b. compliance standard procedures for each work unit or function at BPR and BPR Syariah, including:

1. the obligation for every BPR and BPR Syariah work unit to conduct operational activities in accordance with internal regulations and statutory regulations, including Sharia Principles for BPR Syariah; and
2. the obligation to adjust internal BPR and BPR Syariah regulations with the latest statutory regulations, including Sharia Principles for BPR Syariah;
   c. management decision-making procedures regarding the compliance function;
   d. compliance code of ethics to support the creation of a compliance culture; e. coordination flow and monitoring procedures between:
3. the Director overseeing the compliance function and other Directors;
4. the Director overseeing the compliance function and the compliance work unit or Executive Officer implementing the compliance function; and
5. the compliance work unit or Executive Officer implementing compliance with other work units;
   f. internal regulations regarding the implementation of the compliance function governing duties and responsibilities, including:
6. duties and responsibilities of the Director overseeing the compliance function; and
7. duties and responsibilities of the compliance work unit or Executive Officer implementing the compliance function.

9. The compliance work unit and Executive Officer implementing the compliance function formulate compliance work guidelines, systems, and procedures considering:
   a. internal factors, including organizational structure development plans and findings regarding weaknesses or deviations; and b. external factors, including changes in statutory regulations, adjustments to financial accounting standards, and fatwas issued by authorities having the power to issue fatwas in the Sharia field for BPR Syariah.

V. COMPLIANCE FUNCTION IMPLEMENTATION REPORTS

In accordance with Article 76 paragraph (1) of the POJK on the Implementation of BPR and BPR Syariah Governance, BPR and BPR Syariah are required to formulate and submit compliance function implementation reports. Compliance function implementation reports consist of:

1. The main report on the duties of the Director overseeing the compliance function, covering:
   a. General information on BPR and BPR Syariah according to current conditions, including:

1. human resource formation consisting of Directors, Commissioners, DPS members, committee members, and Executive Officers; and
2. internal regulations possessed, including implementation dates.
   b. Information regarding the implementation of the compliance function, including:
3. the implementation of continuous socialization and training for all BPR and BPR Syariah work units, regarding Financial Services Authority regulations and other statutory regulations, including fatwas issued by authorities having the power to issue fatwas in the Sharia field for BPR Syariah;
4. the results of the Board of Commissioners' supervision over the implementation of the compliance function, and the follow-up by the Director overseeing the compliance function regarding the implementation of compliance culture and compliance functions across all BPR and BPR Syariah work units, including plans to adjust internal regulations that are not yet in accordance with regulations and the fulfillment of organizational structure or human resources;
5. deviations from statutory regulations, including Sharia Principles for BPR Syariah, including explanations of efforts made to prevent deviations; and
6. the implementation of fulfillment of commitments to the Financial Services Authority and other authorities such as the Deposit Insurance Agency, Bank Indonesia, and the Transaction Reports and Analysis Center.

The main report on the duties of the Director overseeing the compliance function, formulated and signed by the Director overseeing the compliance function, is part of the governance implementation report submitted semi-annually, no later than January 31 for the position report ending in December and July 31 for the position report ending in June, through the Financial Services Authority's reporting system, namely the Online Reporting Application (APOLO).

The format of the main report on the duties of the Director overseeing the compliance function is as specified in Appendix II, which is an integral part of this Financial Services Authority Circular.

2. Special reports regarding Board of Directors policies and/or decisions that, in the opinion of the Director overseeing the compliance function, have deviated from Financial Services Authority regulations and/or other statutory regulations and endanger the continuity of BPR and BPR Syariah business.

Special reports are included in the category of incidental reports submitted no later than 10 (ten) working days from the discovery of the deviation.

Special reports are signed by the Director overseeing the compliance function and submitted online via the APOLO Incidental Report channel.

VI. CLOSING

1. Upon the effective date of this Financial Services Authority Circular:
   a. Financial Services Authority Circular Number 6/SEOJK.03/2016 concerning the Implementation of Compliance Functions for Rural Credit Institutions; and

This copy is in accordance with the original.
Director of Legal Development
Legal Department signed
Aat Windradi

b. Financial Services Authority Circular Number 11/SEOJK.03/2019 concerning the Implementation of Compliance Functions for Sharia Rural Financing Institutions, are revoked and declared invalid.

2. The provisions in this Financial Services Authority Circular take effect on the date of determination.

Determined in Jakarta on May 26, 2025

EXECUTIVE HEAD OF BANKING SUPERVISOR
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,
DIAN EDIANA RAE signed https://jdih.ojk.go.id/

APPENDIX I
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
REPUBLIC OF INDONESIA
NUMBER 8/SEOJK.03/2025
CONCERNING
THE IMPLEMENTATION OF COMPLIANCE FUNCTIONS FOR RURAL BANKS (BPR) AND SHARIA RURAL BANKS (BPR SYARIAH)

GUIDELINES FOR THE IMPLEMENTATION OF COMPLIANCE FUNCTIONS FOR RURAL BANKS (BPR) AND SHARIA RURAL BANKS (BPR SYARIAH)

TABLE OF CONTENTS
CHAPTER I INTRODUCTION ................................................................................ 3
A. Background .................................................................................... 3
B. General Provisions ................................................................................ 3
C. Objectives................................................................................................. 4
CHAPTER II GENERAL COMPLIANCE POLICIES ..................................................... 5
A. Compliance Culture .............................................................................. 5
B. Implementation of Compliance Functions .............................................................. 6
CHAPTER III DIRECTOR OVERSEEING THE COMPLIANCE FUNCTION ............................................................................................... 8
A. Criteria for Directors Overseeing the Compliance Function ......... 8
B. Appointment, Replacement, Dismissal, and/or Resignation...................................................................................................... 9
C. Duties and Responsibilities............................................................... 10
CHAPTER IV COMPLIANCE WORK UNIT AND EXECUTIVE OFFICER IMPLEMENTING THE COMPLIANCE FUNCTION .................................................... 12
A. Independence in Task Execution ............................................ 12
B. Duties and Responsibilities............................................................... 12
C. Relationship of Compliance Functions with Other Work Units or Units........................................................... 14
D. Coordination Flow and Monitoring Procedures........................................ 15
CHAPTER V REPORTING ON THE IMPLEMENTATION OF COMPLIANCE FUNCTIONS ............................ 17
A. Document Management ....................................................................... 17
B. Internal Scope Reporting................................................................ 17
C. External Reporting............................................................... 17

CHAPTER I
INTRODUCTION
A. Background
Rural Banks (BPR) and Sharia Rural Banks (BPR Syariah) play an important role in driving the regional economy and developing micro, small, and medium enterprises through meeting the public's need for financial services. The increasing complexity of BPR and BPR Syariah business activities, along with rising business competition, results in high risk exposure faced by BPR and BPR Syariah. Therefore, in their management and operations, BPR and BPR Syariah must apply good governance principles, as well as Sharia governance for BPR Syariah.

One important factor in applying Good Governance to BPR and BPR Syariah is through the implementation of an effective compliance function. The implementation of the compliance function is one of the preventive efforts within the framework to mitigate risks for BPR and BPR Syariah. Preventive efforts can be carried out by BPR and BPR Syariah by adhering to various applicable banking regulations to reduce or minimize the risk of BPR and BPR Syariah business activities.

In order to ensure the effective implementation of the compliance function in BPR and BPR Syariah, it is necessary to compile guidelines for the implementation of the compliance function for BPR and BPR Syariah to realize a common understanding of compliance function work and as a minimum standard that must be understood and fulfilled by BPR and BPR Syariah.

B. General Provisions
BPR and BPR Syariah are required to apply good governance integrated with risk management and compliance, supported by necessary policies or procedures. The application of Good Governance on BPR and BPR Syariah is at least manifested in 12 (twelve) factors regulated in the Financial Services Authority Regulation Number 9 of 2024 concerning the Application of Governance for Rural Banks and Sharia Rural Banks (POJK Application of BPR and BPR Syariah Governance). For BPR Syariah, governance factors add 1 (one) assessment factor, namely the implementation of duties, responsibilities, and authority of the Sharia Supervisory Board (DPS) in accordance with the Financial Services Authority Regulation Number 25 of 2024 concerning the Application of Sharia Governance for Sharia Rural Banks. All of these factors are interrelated and complement each other, from the aspect of shareholders, management and committees, organizations under management, to all functions and internal policies regulating them. In addition to the application of the established governance factors, BPR and BPR Syariah must also follow industry dynamics to encourage the application of Good Governance in BPR and BPR Syariah.

Shareholders through the Organ of the General Meeting of Shareholders (GMS) are required to support the development of healthy BPR and BPR Syariah, one of which is by communicating the vision and mission of BPR and BPR Syariah development through support for the implementation of the compliance function. Steps that can be taken include avoiding conflicts of interest and/or intervention for personal or specific group interests.

Furthermore, the actual implementation of the compliance function originates from top management through the obligation of the Board of Directors to ensure BPR and BPR Syariah compliance with statutory regulations, including Sharia Principles for BPR Syariah, and with supervision carried out by the Board of Commissioners and DPS for BPR Syariah. The implementation of the compliance function can run effectively in BPR and BPR Syariah that have a work culture and compliance culture well internalized by all elements in all operational activities. Implementation and supervision of the implementation of the compliance function are carried out with support from organizations, committees, or work units under each management.

C. Objectives
BPR and BPR Syariah must have guidelines for the implementation of the compliance function with the objectives:

1. applying the prudence principle and healthy banking principles consistently to mitigate compliance risks.
2. having a picture in achieving the vision and mission established in the business plan so as to prevent deviations by individuals that can harm BPR and BPR Syariah.
3. protecting stakeholders through compliance with statutory regulations, including Sharia Principles for BPR Syariah.

Furthermore, this compliance function implementation guideline can be further developed and adjusted to the conditions, complexity of business activities, strategies, and vision and mission of each BPR and BPR Syariah.

CHAPTER II
GENERAL COMPLIANCE POLICY
General compliance policy is part of the guidelines for the application of Good Governance of BPR and BPR Syariah at all levels of organization and business activities of BPR and BPR Syariah. General compliance policy contains the main principles of applying compliance culture and the implementation of the compliance function, which serve as the foundation for BPR and BPR Syariah in compiling and evaluating compliance work guidelines, systems, and procedures in more detail. The implementation of this general policy is expected to provide added value for BPR and BPR Syariah and maintain business sustainability.

A. Compliance Culture
The continuous implementation of compliance culture is part of the awareness and prevention steps in efforts to mitigate compliance risks that can impact losses and the reputation of BPR and BPR Syariah. To implement and realize an effective compliance culture, responsible leaders and management are required who serve as role models or examples for all employees. Compliance culture can be done through, among others:

1. Management Commitment
   In principle, all Directors are responsible for creating a compliance culture in all business activities. The Board of Directors is required to foster and realize the implementation of compliance culture at all levels of organization and business activities. Directors who oversee the compliance function are tasked with formulating strategies to encourage the creation of a compliance culture. Meanwhile, the Board of Commissioners supervises the implementation of the compliance function, including compliance culture. For BPR Syariah, DPS supervises the implementation of the compliance function related to the application of Sharia Principles.
2. Commitment of the Compliance Work Unit or Executive Officials Implementing the Compliance Function
   Efforts to create a compliance culture in all business activities are also the tasks and responsibilities of the compliance work unit or Executive Officials implementing the compliance function. The compliance work unit or Executive Officials implementing the compliance function are responsible for making steps to support the creation of a compliance culture in all business activities at each organizational level.
3. Commitment of All Employees
   Compliance culture can be realized through the high concern and commitment of all employees of BPR and BPR Syariah. Compliance culture is expected to create ethical BPR and BPR Syariah employees, thereby influencing the better performance of BPR and BPR Syariah and increasing trust from stakeholders. In addition, compliance culture in BPR and BPR Syariah needs to be introduced as the identity of BPR and BPR Syariah to third parties or partners so that it can convey a message to external parties regarding the compliance principles of BPR and BPR Syariah.

In efforts to build a compliance culture, BPR and BPR Syariah must have strategies that can serve as references for realizing the implementation of good compliance functions at all levels of organization. The implementation strategy of compliance culture also needs to be aligned with the work culture philosophy (corporate culture) of BPR and BPR Syariah and in line with the company's vision and mission. Compliance culture implementation strategies, for example:

1. Having good and written policies, systems, and procedures for every business activity and activity carried out by BPR and BPR Syariah. The compilation of such policies, systems, and procedures reflects the commitment of BPR and BPR Syariah to always comply with internal and external regulations.
2. Having a compliance work unit and Executive Officials implementing the compliance function, tasked with compiling, implementing, and monitoring compliance culture programs in each relevant work unit.
3. Conducting communication, including carrying out socialization, related to the implementation of compliance to all employees of BPR and BPR Syariah. Continuous communication can accelerate the internalization process of compliance culture so that compliance becomes a culture for all employees of BPR and BPR Syariah.
4. Building good communication between the compliance work unit or Executive Officials implementing the compliance function with other work units, including in the reporting process. Coordination is carried out with other work units or Executive Officials handling risk management, internal audit, or other work units to identify potential risks.
5. Having a disciplinary scheme or imposition of sanctions on employees if there is non-compliance with internal or external regulations, among others by referring to the employee discipline policies or regulations of each BPR and BPR Syariah. Conversely, BPR and BPR Syariah can also have a reward scheme for employees who provide compliance examples. The compliance work unit and Executive Officials implementing the compliance function need to involve management levels and Executive Officials in other work units or units responsible for ensuring the implementation of compliance culture in each respective work unit or unit (compliance culture leader).

To ensure that the implementation of compliance culture runs effectively and measurably, the compliance work unit and Executive Officials implementing the compliance function can compile periodic and hierarchical compliance culture assessment mechanisms. Furthermore, the assessment results are monitored for the implementation of follow-up improvements according to areas requiring increased implementation of the compliance function.

B. Implementation of the Compliance Function
The compliance function has general principles that can serve as references in carrying out the role and function of compliance, including actions, among others:

1. realizing the implementation of compliance culture at all levels of organization and business activities of BPR and BPR Syariah;
2. managing compliance risks faced by BPR and BPR Syariah, coordinating with the risk management organization;
3. ensuring that policies, regulations, systems and procedures, and business activities carried out by BPR and BPR Syariah are in accordance with Financial Services Authority regulations and other statutory regulations, including Sharia Principles for BPR Syariah; and
4. ensuring compliance with commitments made by BPR and BPR Syariah to the Financial Services Authority and/or other authorities.

The implementation of the compliance function is in principle one of the implementations of the three lines of defense model framework, namely the business management line, the risk and compliance management line, and the internal audit line. The compliance function is one part of the management function in carrying out the role of the second line, which functions to support the business management line in supervising compliance with statutory regulations, including Sharia Principles for BPR Syariah, and ethical values. The Board of Commissioners, as a representative of the governing organ, actively supervises and provides suggestions for improving the quality of compliance function implementation. For BPR Syariah, DPS actively supervises and provides suggestions for improving the quality of compliance function implementation related to Sharia Principles.

The implementation of the compliance function can be carried out centrally (centralised compliance function), meaning all compliance staff are placed in one work unit or department/division, or decentralised (decentralised compliance function), meaning compliance staff are placed in various different business lines. This is done by considering the size or complexity of the business and/or the scope of office networks.

CHAPTER III
DIRECTORS OVERSEEING THE COMPLIANCE FUNCTION
BPR and BPR Syariah have Directors who oversee the compliance function, tasked with ensuring the implementation of the compliance function of BPR and BPR Syariah. Nevertheless, compliance implementation is essentially the task and responsibility of all Directors, carried out through, among others:

1. understanding and complying with statutory regulations and internal regulations;
2. fostering and realizing the implementation of compliance culture at all levels of organization and business activities;
3. establishing compliance policies proposed by Directors overseeing the compliance function and communicating them to all levels of organization;
4. establishing compliance work units and/or assigning or appointing Executive Officials implementing the compliance function; and
5. supporting compliance work plans, continuously improving the compliance function, and internalizing compliance policies.

A. Criteria for Directors Overseeing the Compliance Function

1. Directors overseeing the compliance function in BPR and BPR Syariah with core capital of at least IDR 50,000,000,000.00 (fifty billion rupiah) must be independent and prohibited from overseeing:
   a. fund collection and fund disbursement; b. logistics and procurement of goods or services; and
   c. other operational activities.
   Other operational activities include information technology, finance, and accounting.
2. Directors overseeing the compliance function in BPR and BPR Syariah with core capital of less than IDR 50,000,000,000.00 (fifty billion rupiah) may carry out tasks and responsibilities in a limited manner in the functions referred to in number 1 but do not make decisions on operational activities.
3. Candidate Directors overseeing the compliance function must have integrity, good financial reputation, and competence, including adequate knowledge of Financial Services Authority regulations and other statutory regulations, including Sharia Principles for BPR Syariah, especially those related to the business activities and activities of BPR and BPR Syariah.
4. Directors overseeing the compliance function may become members of committees formed by the Board of Directors while maintaining independence and aiming to support the implementation of the compliance function. As an example, Directors overseeing the compliance function become members of the Risk Management Committee.
5. The majority of Directors are prohibited from having family relationships up to the second degree with other Directors, members of the Board of Commissioners, and/or members of DPS. BPR and BPR Syariah can regulate in their internal regulations that Directors overseeing the compliance function are Directors who do not have family relationships up to the second degree with other Directors, members of the Board of Commissioners, and/or members of DPS to increase their independence.

B. Appointment, Replacement, Dismissal, and/or Resignation

1. The appointment, replacement, dismissal, and/or resignation of Directors overseeing the compliance function are carried out in accordance with Financial Services Authority Regulations concerning BPR and BPR Syariah and other statutory regulations.
2. In the event that Directors overseeing the compliance function are permanently unable to perform duties, resign, or their term of office expires, BPR and BPR Syariah are required to immediately appoint a replacement for Directors overseeing the compliance function. BPR and BPR Syariah determine the time limit for appointing a replacement for Directors overseeing the compliance function after the Directors overseeing the compliance function are permanently unable to perform duties, resign, or their term of office expires, for example, at most 60 (sixty) working days.
   The determination of the time limit by BPR and BPR Syariah is carried out by considering the effectiveness of the implementation of the compliance function and the potential for increased risk.
3. In the event that Directors overseeing the compliance function are temporarily unable to perform their duties for more than a certain period consecutively, the execution of the relevant duties is temporarily replaced by officials below the Directors overseeing the compliance function, namely the head of the compliance work unit or Executive Officials implementing the compliance function.
   The certain consecutive period is determined by each BPR and BPR Syariah in internal policies, for example, for more than 10 (ten) consecutive working days and at most 60 (sixty) working days. The maximum time limit of 60 (sixty) working days is the limit for temporary inability.
   The determination of the time limit by BPR and BPR Syariah is carried out by considering the effectiveness of the implementation of the compliance function and the potential for increased risk.
4. Candidate Directors replacing Directors overseeing the compliance function as referred to in number 2 and officials below Directors overseeing the compliance function as referred to in number 3 must meet the provisions regarding concurrent positions and criteria as referred to in letter A.
5. The head of the compliance work unit or Executive Officials implementing the compliance function who temporarily replace the position of Directors overseeing the compliance function as referred to in number 3 are reported to the Financial Services Authority Office supervising BPR and BPR Syariah.

C. Duties and Responsibilities

1. Directors overseeing the compliance function have at least the following duties and responsibilities:
   a. formulating strategies to encourage the creation of compliance culture carried out through, among others:

1. compiling and submitting proposals to the Board of Directors regarding compliance policies oriented towards the vision, mission, and values of the company and in line with the direction and policy of BPR and BPR Syariah business development in the long term;
2. compiling compliance policies and evaluating the effectiveness of compliance culture and work culture assessments by considering appropriate rewards (reward) and discipline (punishment), such as the implementation of compliance culture campaigns; and
3. continuous improvement of compliance competence, such as organizing training or self-learning programs, especially for human resources in the compliance field. For BPR Syariah, continuous improvement of Sharia compliance function competence is also required, among others through training or learning programs related to Sharia Principles;
   b. ensuring that BPR and BPR Syariah business activities meet all statutory regulations, including Sharia Principles for BPR Syariah, through, among others:
4. establishing compliance systems and procedures and establishing or evaluating internal regulations and guidelines of BPR and BPR Syariah;
5. adjusting internal policies and guidelines of BPR and BPR Syariah to changes in statutory regulations, including fatwas issued by institutions with authority to issue fatwas in the Sharia field for BPR Syariah;
6. establishing necessary steps and preventing optimally so that the Board of Directors does not establish policies or decisions deviating from Financial Services Authority regulations and other statutory regulations, including Sharia Principles for BPR Syariah;
7. reviewing the procedures or decision-making methods by management, including procedures for providing dissenting opinions if there are policies or decisions that do not comply with statutory regulations and internal regulations;
8. following up on deviations carried out by Directors, and reporting to other Directors, members of the Board of Commissioners, and/or the Financial Services Authority. Reports to the Board of Commissioners can be accompanied by a draft warning letter to Directors who deviated to be signed;
9. ensuring the settlement of commitments by the Board of Directors and relevant work units, both commitments to the Financial Services Authority and other authorities;
10. making efforts to minimize compliance risks; and
11. coordination with DPS regarding the implementation of compliance function tasks in fulfilling Sharia Principles for BPR Syariah.
    c. carrying out other tasks related to the implementation of the compliance function, among others:
12. organizing socialization of internal regulations and statutory regulations, including fatwas issued by institutions with authority to issue fatwas in the Sharia field for BPR Syariah, and evaluating their implementation;
13. following up on data or information requests by authorities; and
14. providing suggestions or responses to questions and problems from internal work units.

2. In carrying out duties and responsibilities, Directors overseeing the compliance function, including through compliance work units or Executive Officials overseeing the compliance function, can act and carry out activities, among others:
   a. accessing all relevant internal documents, data, and/or information of BPR and BPR Syariah with tasks and responsibilities in the implementation of the compliance function; b. having access to the Board of Commissioners, Board of Directors, and DPS in relation to the implementation of the compliance function; and
   c. requesting information or explanations from all employees of BPR and BPR Syariah to facilitate the implementation of duties and responsibilities.
3. The duties and responsibilities as referred to in number 1 do not eliminate the rights and obligations of Directors overseeing the compliance function as Directors of BPR and BPR Syariah in accordance with statutory regulations governing the legal entity of BPR and BPR Syariah, if decisions are required for certain actions by all Directors of BPR and BPR Syariah. Directors overseeing the compliance function can still assist other Directors as long as they can ensure the fulfillment of segregation of duties by performing check and balance or balancing as control over business decisions taken by BPR or BPR Syariah, such as ensuring the fulfillment of all internal regulations and guidelines during the analysis process until approval.

CHAPTER IV
COMPLIANCE WORK UNITS AND EXECUTIVE OFFICERS IMPLEMENTING COMPLIANCE FUNCTIONS

A. Independence in Task Implementation

1. Compliance work units and Executive Officers implementing compliance functions must be independent, formed or appointed separately, and free from the influence of other work units, having access to and reporting directly to the Board of Members responsible for the compliance function.

2. Personnel and staff within the compliance work unit are prohibited from holding positions that involve conflicts of interest in carrying out the tasks and responsibilities of the compliance function.

3. The Head of the Compliance Work Unit must meet independence requirements, namely not handling fund disbursement, fund mobilization, procurement of goods and services, and other operational activities. Executive Officers implementing compliance functions may assist in fund disbursement, fund mobilization, procurement of goods and services, and other operational activities but must not handle matters related to operational decision-making.

4. The Head of the Compliance Work Unit and Executive Officers implementing compliance functions must:
   a. understand the regulations of the Financial Services Authority (OJK) and other applicable laws and regulations, including Sharia Principles for Sharia Rural Banks (BPR Syariah), particularly those related to business activities and BPR/BPR Syariah activities; and b. have a commitment to implement and develop a compliance culture. BPR and BPR Syariah may determine competency certificate requirements from professional certification bodies for the Head of the Compliance Work Unit or Executive Officers implementing compliance functions to ensure their competence, for example, in the fields of governance, risk, and compliance.

5. The appointment, replacement, and/or dismissal of the Head of the Compliance Work Unit or Executive Officers implementing compliance functions must be reported to the Financial Services Authority (OJK) online through the OJK reporting system in monthly periodic reports, in accordance with the procedures specified in the Financial Services Authority Circular Letter regarding reporting through the OJK reporting system and financial condition transparency for BPR, and the Financial Services Authority Circular Letter regarding reporting through the OJK reporting system and financial condition transparency for BPR Syariah.

B. Duties and Responsibilities

The Compliance Work Unit or Executive Officers implementing compliance functions have at least the following duties and responsibilities:

1. Formulating strategies to foster a compliance culture, carried out through, inter alia:
   a. preparing programs to enhance compliance culture across all BPR and BPR Syariah activities and every organizational level, such as work culture campaigns with compliance values; b. preparing programs for continuous competency enhancement, such as training for all relevant work units regarding relevant laws and regulations, including Sharia Principles for BPR Syariah, and self-learning programs; and
   c. providing information regarding policies or applicable laws and regulations, including Sharia Principles for BPR Syariah, that are easily accessible and understood by every work unit;

2. Ensuring that BPR and BPR Syariah business activities comply with all applicable laws and regulations, including Sharia Principles for BPR Syariah, through, inter alia:
   a. ensuring the application and evaluating policies, regulations, systems, and procedures owned by BPR and BPR Syariah in conducting activities have complied with applicable laws and regulations, including Sharia Principles for BPR Syariah, including conducting compliance testing on decisions or plans for cooperation agreements; b. analyzing the impact of policies or regulations on BPR and BPR Syariah operations and business activities, including laws, government regulations, Financial Services Authority regulations, Bank Indonesia regulations, Deposit Insurance Agency regulations, ministry regulations, and relevant local regulations, including fatwas issued by institutions with authority to issue fatwas in the Sharia field for BPR Syariah;
   c. conducting reviews and/or recommending adjustments to policies, regulations, systems, and procedures owned by BPR and BPR Syariah to comply with applicable laws and regulations, including Sharia Principles for BPR Syariah;
   d. reporting the implementation of the compliance function and compliance violations to the Board of Members responsible for the compliance function, including proposing compliance policy improvements, if any; e. monitoring compliance levels regarding regulations (including maximum credit limits, maximum fund disbursement limits, minimum capital fulfillment requirements, and cash ratios) and regarding the imposition of sanctions or fines by authorities; f. preparing programs and work plans and conducting identification, measurement, monitoring, and control of compliance risks in coordination with the risk management work unit or Executive Officers responsible for applying risk management functions; and g. coordinating and providing recommendations to the internal audit work unit or Executive Officers implementing internal audit functions regarding compliance violations committed by BPR and BPR Syariah employees; and

3. Carrying out other tasks related to the implementation of compliance functions, including:
   a. conducting socialization of internal regulations and relevant applicable laws and regulations to all work units, including fatwas issued by institutions with authority to issue fatwas in the Sharia field for BPR Syariah, and evaluating the effectiveness of such socialization periodically; b. following up on data or information requests for banking supervision required by the Financial Services Authority (OJK) and/or other supervisory authorities in carrying out supervision of BPR and BPR Syariah;
   c. preparing and managing media for monitoring commitment fulfillment to authorities, including coordination and communication with authorities and/or commitments to the Board of Commissioners and Sharia Supervisory Board (DPS);
   d. providing consultation, verification, or responses to relevant work units or BPR and BPR Syariah employees regarding compliance with Financial Services Authority (OJK) regulations and other applicable laws and regulations, including Sharia Principles for BPR Syariah, including the implementation of BPR and BPR Syariah products and business activities, plans for cooperation agreements, credit or financing decisions, and matters related to asset management; and e. preparing and/or drafting reports, including compliance work plans and reports on the implementation of the compliance function.

C. Relationship Between Compliance Functions and Other Work Units or Units

1. The Compliance Work Unit or Executive Officers implementing compliance functions may coordinate with other work units or units to facilitate task implementation when applying compliance functions.

2. BPR and BPR Syariah formulate coordination policies between the Compliance Work Unit or Executive Officers implementing compliance functions and every other work unit or unit existing within each respective BPR and BPR Syariah.

3. The Compliance Work Unit or Executive Officers implementing compliance functions are responsible for managing compliance risks. In the event that a work unit or unit has compliance risk exposure, the respective work unit or unit must immediately inform the Compliance Work Unit or Executive Officers implementing compliance functions for further action in accordance with regulations.

4. In carrying out compliance risk management, the Compliance Work Unit or Executive Officers implementing compliance functions coordinate with the risk management work unit or Executive Officers responsible for applying risk management functions.

5. In ensuring compliance with applicable laws and regulations, including Sharia Principles for BPR Syariah, the Compliance Work Unit or Executive Officers implementing compliance functions actively monitor and coordinate with other work units or units to meet regulatory requirements relevant to BPR and BPR Syariah business activities.

6. In ensuring compliance with commitments made by BPR and BPR Syariah to authorities and/or commitments of work units or units to the Board of Commissioners and Sharia Supervisory Board (DPS), the Compliance Work Unit or Executive Officers implementing compliance functions actively monitor and coordinate with other work units or units regarding the fulfillment and/or evaluation of such commitments.

7. The Compliance Work Unit or Executive Officers implementing compliance functions are also subjects of audits or reviews by the internal audit work unit or Executive Officers implementing internal audit functions. Nevertheless, the Compliance Work Unit or Executive Officers implementing compliance functions cooperate with the internal audit work unit or Executive Officers implementing internal audit functions to improve the effectiveness of control functions.

8. In the event that BPR and BPR Syariah apply a whistleblowing system, the Compliance Work Unit or Executive Officers implementing compliance functions coordinate with the internal audit work unit or Executive Officers implementing internal audit functions regarding follow-up on reported allegations and the implementation of investigations.

D. Coordination Flow and Monitoring Procedures

1. In carrying out duties and responsibilities as referred to in letter B, the Head of the Compliance Work Unit or Executive Officers implementing compliance functions may form work units or small teams with primary tasks, such as:
   a. compliance advisory, which conducts activities such as managing approvals or reporting on products and/or activities, preparing responses to relevant work units or employees regarding compliance, and managing coordination or communication with authorities; b. regulatory compliance, which conducts activities such as preparing summaries of current applicable laws and regulations, preparing impact analyses of applicable laws and regulations, and monitoring follow-up on impact analysis results; and
   c. compliance assessment, which conducts activities such as preparing policies and assessments in compliance testing, managing compliance testing results, and monitoring them.

2. BPR and BPR Syariah formulate coordination flows and monitoring procedures between work units or teams within the Compliance Work Unit or Executive Officers implementing compliance functions and other work units.

Example:
Product Implementation
In implementing new products, the compliance advisory work unit within the Compliance Work Unit or Executive Officers implementing compliance functions conducts the following main activities:
a. receiving requests for responses or opinions regarding the implementation of new products submitted by work units handling products internally within BPR and BPR Syariah; b. conducting analysis and ensuring document completeness before submitting reports or requests for approval for new product implementation to the Financial Services Authority (OJK) or relevant authorities;
c. monitoring the approval request process submitted to the Financial Services Authority (OJK) until the new product obtains approval from the Financial Services Authority (OJK);
d. receiving reports on the realization of new product implementation within a certain period after the implementation of new products from work units handling products internally within BPR and BPR Syariah before submitting reports to the Financial Services Authority (OJK); e. analyzing the suitability of reports on the realization of new product implementation for subsequent reporting to the Financial Services Authority (OJK); and f. coordinating with the Sharia Supervisory Board (DPS) regarding compliance with Sharia Principles, for BPR Syariah.

3. BPR and BPR Syariah formulate coordination flows and monitoring procedures between the Compliance Work Unit or Executive Officers implementing compliance functions and other work units, including fund disbursement work units, fund mobilization work units, human resources work units, risk management work units, Anti-Money Laundering (APU), Combating the Financing of Terrorism (PPT), and Combating Proliferation Financing (PPSPM) work units, adjusted to the complexity and operations of each, including the duties and responsibilities of each personnel within them.

CHAPTER V
REPORTING ON THE IMPLEMENTATION OF COMPLIANCE FUNCTIONS

A. Document Management

1. BPR and BPR Syariah store and maintain all documents or archives related to the implementation of compliance functions as evidence that the implementation of compliance functions has been carried out in accordance with regulations.

2. The Compliance Work Unit or Executive Officers implementing compliance functions periodically review data and/or information used as the basis for carrying out operational activities.

3. The review of such data and/or information is coordinated with relevant work units or units and submitted to all interested parties to ensure that the data and/or information managed are in good condition and can meet the needs of interested parties.

4. The management of documents, data, and/or archives related to the implementation of compliance functions is carried out in accordance with applicable internal regulations of each respective BPR and BPR Syariah.

B. Internal Scope Reporting

1. In the event that the Board of Members responsible for the compliance function does not serve as the President Director, the Board of Members responsible for the compliance function reports the implementation of their duties and responsibilities periodically to the President Director, with copies to the Board of Commissioners and the Sharia Supervisory Board (DPS) for BPR Syariah. The periodic period is adjusted to internal policies of each BPR and BPR Syariah, for example, quarterly.

2. The Compliance Work Unit or Executive Officers implementing compliance functions report the implementation of their duties and responsibilities periodically to the Board of Members responsible for the compliance function. The periodic period is adjusted to internal policies of each BPR and BPR Syariah and is conducted before the deadline for submission of reports to external parties.

3. As an effort to detect indications of violations in internal work units or units, BPR and BPR Syariah may apply a whistleblowing system with the active role of every BPR and BPR Syariah employee. The Compliance Work Unit or Executive Officers implementing compliance functions regulate the rights and protections provided to every reporter as stipulated in policies and systems and procedures regarding the whistleblowing system.

C. Reporting to External Parties

1. Reporting by the Board of Members responsible for the compliance function to the Financial Services Authority (OJK)
   a. The Board of Members responsible for the compliance function submits reports on the implementation of their duties, including:
   1) The main report on the implementation of duties of the Board of Members responsible for the compliance function, with the scope as regulated in this Financial Services Authority Circular Letter; and
   2) Special reports regarding policies and/or Board decisions that, in the opinion of the Board of Members responsible for the compliance function, have deviated from Financial Services Authority (OJK) regulations and/or other applicable laws and regulations, including Sharia Principles for BPR Syariah, and endanger the continuity of BPR and BPR Syariah business.
   b. The reports referred to in letter a number 1) are signed by the Board of Members responsible for the compliance function and submitted to the Financial Services Authority (OJK) semi-annually, no later than January 31 for reports on the final position of December, and July 31 for reports on the final position of June, with copies to the Board of Commissioners, President Director, and Sharia Supervisory Board (DPS) for BPR Syariah.
   c. Special reports as referred to in letter a number 2) are submitted to the Financial Services Authority (OJK) no later than 10 (ten) working days from the discovery of the deviation.

2. The guidelines for applying compliance functions prepared by BPR and BPR Syariah regulate the coordination flow between the Board of Directors responsible for the compliance function and the Compliance Work Unit or Executive Officers responsible for the compliance function, as well as the Sharia Supervisory Board (DPS) for BPR Syariah, before the submission deadline as referred to in number 1.

Determined in Jakarta on May 26, 2025
EXECUTIVE HEAD OF BANKING SUPERVISOR
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,
DIAN EDIANA RAE
Signed

APPENDIX II
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
REPUBLIC OF INDONESIA
NUMBER 8/SEOJK.03/2025
REGARDING
THE IMPLEMENTATION OF COMPLIANCE FUNCTIONS FOR RURAL BANKS AND SHARIA RURAL BANKS

MAIN REPORT ON THE IMPLEMENTATION OF DUTIES
OF THE BOARD OF MEMBERS RESPONSIBLE FOR THE COMPLIANCE FUNCTION

A. General Information on BPR or BPR Syariah

1. Human Resources Formulation

Name	NIK	Position	Employment Status	Education Level	Tenure
Filled with position choice: <br> - President Director <br> - Director responsible for compliance function <br> - Director <br> - Chief Commissioner <br> - Commissioner <br> - Independent Commissioner <br> - Head of Sharia Supervisory Board (DPS) <br> - Member of Sharia Supervisory Board (DPS) <br> - Audit Committee <br> - Risk Monitoring Committee <br> - Remuneration and Nomination Committee <br> - Risk Management Committee <br> - Other Committees <br> - Executive Officer Compliance <br> - Executive Officer Risk Management <br> - Executive Officer Internal Audit <br> - Executive Officer APU PPT <br> - Executive Officer Sharia Compliance <br> - Executive Officer Sharia Risk Management <br> - Executive Officer Sharia Internal Audit <br> - Other Executive Officers			Filled with choice: <br> - "New Appointment" <br> - "Re-appointment" <br> - "Position Change" <br> - "Unchanged"	Filled with choice: <br> - "S3" <br> - "S2" <br> - "S1" <br> - "D3" <br> - "High School (SLTA)" <br> - "Other"	Filled with appointment date and output is the tenure based on the reporting period.

Note:
Sharia Executive Officer Compliance, Sharia Executive Officer Risk Management, or Sharia Executive Officer Internal Audit can be selected if BPR Syariah has separate Sharia compliance, risk management, or internal audit Executive Officers.

2. Internal Regulations Owned by BPR or BPR Syariah

Regulation Title	Regulation Number	Internal Regulation Date	Implementation Date	Notes
		Filled with the effective date of the internal regulation.	Filled with the work unit or unit that prepared the internal regulation or other relevant information.

B. Information Regarding the Implementation of Compliance Functions

1. Implementation of Socialization and Continuous Training

Topic of Socialization/Training	Implementation Date	Implementing Party	Name of Implementing Party	Participant Category	Notes on Participants	Number of Participants	Activity Description
	Filled with implementation start date.	Filled with choice: <br> - "Internal BPR or BPR Syariah" <br> - "External BPR or BPR Syariah" <br> - "Collaborating with other institutions"	Filled if Implementing Party column is filled with "External BPR or BPR Syariah" or "Collaborating with other institutions"	Filled with choice: <br> - "All employees" <br> - "Board of Directors, Board of Commissioners, and/or DPS for BPR Syariah" <br> - "Work Units or Executive Officers" <br> - "Committees"	Filled if Participant Category column is filled with "Work Units or Executive Officers" or "Committees" by explaining the work unit, Executive Officers, or committees that are participants.

2. Implementation of Compliance Culture and Compliance Functions, including Sharia Principles for BPR Syariah

No.	Results of Board of Commissioners Supervision on Compliance Function Implementation	Follow-up and Implementation of Compliance Culture and Compliance Functions	Notes
	Filled with follow-up actions taken by the Board of Members responsible for the compliance function regarding the results of Board of Commissioners supervision, as well as the implementation of compliance culture and compliance functions.

3. Deviations from Applicable Laws and Regulations, including Sharia Principles for BPR Syariah

No.	Regulation Violated	Discovery Date	Description of Deviation	Efforts Made to Prevent Deviation	Status of Regulation Resolution
		Filled with discovery start date.			Filled with choice: <br> - "Completed" <br> - "In Process" <br> - "Not Yet Followed Up"

Note:
BPR and BPR Syariah filling the Status of Regulation Resolution with "In Process" and "Not Yet Followed Up" must resubmit the Report on Deviations from Applicable Laws and Regulations in subsequent reporting periods until the resolution status is filled with "Completed".

4. Implementation of Fulfillment of Commitments to Authorities

No.	Description of Commitment	Party Giving Commitment	Implementation of Commitment	Party Implementing Commitment	Status of Commitment Implementation
		Filled with internal BPR or BPR Syariah organ handling commitment implementation, e.g., Board of Directors, Board of Commissioners, DPS, specific work units or Executive Officers.			Filled with choice: <br> - "Completed" <br> - "In Process" <br> - "Not Yet Followed Up"

Note:
BPR and BPR Syariah filling the Status of Commitment Implementation with "In Process" and "Not Yet Followed Up" must resubmit the Report on Implementation of Fulfillment of Commitments to Authorities in subsequent reporting periods until the resolution status is filled with "Completed".

Determined in Jakarta on May 26, 2025
EXECUTIVE HEAD OF BANKING SUPERVISOR
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA,
DIAN EDIANA RAE
Signed