The Financial Services Authority (Otoritas Jasa Keuangan – “OJK”) has become aware of several types of misconduct that are commonly perpetrated by investment managers. Particularly common are types of misconduct that relate to the mandatory independence of investment managers. [1] Moreover, cases have also emerged that involve disparities between the levels of liquidity of investment products and the need of clients to complete redemptions of their funds, which has led to failed payments. Against this background, the OJK has now extensively updated the Guidelines on the Conduct of Investment Managers through the issuance of Regulation No. 17/POJK.04/2022 (“Regulation 17/2022”). [2]
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