Corruption is always a dishonest and fraudulent act, regardless of whether it occurs within the public or private sectors. The fall of the so-called “New Order” regime in 1998 marked a new chapter in Indonesia in terms of anti-corruption initiatives. Now, after 19 years of reform efforts, policies aimed at addressing corruption involving government officials within the public sector have become the primary expression of Indonesia’s anti-corruption efforts and fill the national media. As a consequence of this, the role of private entities which are involved in acts of corruption is sometimes seen as less important. However, the Vice Chairman of Indonesia’s official Corruption Eradication Commission (KPK), Laode M Syarif, has revealed that most of the corruption cases investigated by the KPK involve private entities. Indeed, in 2006, some 156 people working for private entities were named suspects by the KPK.[1] 
 
In general, acts of corruption committed by and through private entities can be divided into two main categories, specifically external acts involving the bribery of third parties, including government officials, and internal acts involving corruption within a given organization. Unfortunately though, the regulatory framework which addresses the management of anti-bribery or anti-corruption efforts by private entities remains limited.
 
In order to offer a response to this pressing issue, the International Organization for Standardization introduced ISO 37001:2016 on Anti-Bribery Management Systems in October of 2016. This standard was subsequently acknowledged by the National Standardization (“BSN”) Agency through the issuance of Decree No. 248 of 2017. ISO 37001:2016 sets out a list of anti-bribery guidelines and standards to be followed and implemented by both public and private organizations, including the not-for-profit sector. These standards specifically encompass a step-by-step approach for the establishment of an anti-bribery culture under the supervision of an anti-bribery compliance function.
 
ISO 37001:2016 more recently came to the public’s attention when the new governor of the Special Capital Region of Jakarta, Anies Baswedan, expressed his commitment to implementing ISO 37001:2016 within regional government,[2] in addition to other popular promises which were made by Baswedan during his campaign, including pledges to introduce a 0% Down Payment (“DP”) scheme for affordable housing, to discontinue the reclamation of Jakarta Bay, to offer financial assistance for starts-up, etc.[3]
 
In order to shed a little light on ISO 37000:2016, as well as to further discuss the commitment of the new governor of the Special Capital Region of Jakarta to this standard, this edition of Indonesia Law Digest (ILD) will elaborate upon the basic concepts and key aspects which underlie ISO 37001:2016, as detailed below: