In response to the increasing risks relating to the provision of financial services and products, as well as to the recommendations made by the Financial Action Task Force on Money Laundering
[1], the Financial Services Authority (
Otoritas Jasa Keuangan – “
OJK”) has issued Regulation
No. 12/POJK.01/2017 on the Implementation of Anti-Money-Laundering and Prevention-of-Terrorism-Financing Programs Within the Financial Sector (“
Regulation 12/2017”).
[2]
In essence, Regulation 12/2017 is aiming to improve the implementation of anti-money-laundering and prevention-of-terrorism-financing (
anti pencucian uang dan pencegahan pendanaan terorisme – “
APU-PPT”) programs through the implementation of a risk-based approach.
[3]
With these goals in mind, Regulation 12/2017 merges and strengthens previous guidelines for providers of financial services within the banking, capital market and non-banking sectors (collectively referred to as “
Providers”)
[4] which covered the implementation of APU-PPT programs. These guidelines were previously regulated under the following regulations (collectively referred to as “
Previous Regulations”):
[5]
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