The Financial Services Authority (Otoritas Jasa Keuangan - “OJK”) recently issued Regulation No. 39/POJK.03/2019 on the Implementation of Anti-Fraud Strategies by Commercial Banks (“Regulation 39/2019”) in an effort to further minimize the risk of the occurrence of fraud (including deception, financial fraud, embezzlement of assets, information leaks, criminal banking offenses and other activities which can be deemed the equivalent of fraud) during the operational activities of banks.[1] In order to achieve this objective, Regulation 39/2019 essentially updates provisions that pertain to the implementation of anti-fraud strategies by commercial banks (“Banks”). Said provisions specifically address the following areas:
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