Indonesia

I. Introduction The rapid digital transformation has integrated children into the online world at a dizzying pace, through a variety of electronic products, services, and features, including smartphon...

Indonesian Fintech Business Update: Data Exchange Cooperation under Indonesian Financial Services Authority (OJK) Regulation No. 10/POJK.

Murzal & Partners (MNP) is pleased to announce the signing of a strategic Memorandum of Understanding (MoU) with the Ministry of Manpower of the Republic of Indonesia, signaling a pivotal step forward in the joint effort to support entrepreneurship and modernize regulatory frameworks in alignment with Indonesia’s evolving economic ambitions. The MoU, signed on 30 April 2025, mandates MNP to assist in two key areas: (i) providing legal support and training for emerging entrepreneurs across Indonesia, and (ii) contributing legal insights during regulatory policy development discussions hosted by the Ministry. This collaboration reinforces the government’s commitment to fostering an inclusive, business-friendly ecosystem — while recognizing the increasingly sophisticated needs of both local and international investors. A Proactive Government Response to Market Momentum The Ministry’s initiative comes in direct response to Indonesia’s strong and sustained economic performance, underscored by consistent GDP growth and a rising influx of domestic and foreign investment. From digital innovation and renewable energy to manufacturing and infrastructure, Indonesia is rapidly becoming one of Southeast Asia’s most attractive investment destinations. Recognizing this momentum, the Ministry of Manpower is proactively working to reshape the regulatory landscape to ensure it remains agile, transparent, and conducive to long-term economic growth. The MoU with MNP serves as a cornerstone of this approach — and a signal to the market that Indonesia is serious about aligning regulation with business realities. “This MoU reflects not only the Ministry’s forward-looking policy stance, but also Indonesia’s recognition of the vital role the legal profession plays in shaping sustainable economic development,” said Jufrian Murzal, MNP’s Managing Partner. “We’re honoured to partner with the Ministry at such a critical time and contribute directly to both policy dialogue and entrepreneurial empowerment.” From Agreement to Action: Execution Phase Underway With the MoU now formalized, both MNP and the Ministry have swiftly shifted their focus to the execution of commitments outlined in the agreement. MNP’s legal experts are currently working closely with Ministry officials to design and deliver targeted training programs for aspiring entrepreneurs, particularly in areas of regulatory compliance, licensing, employment law, and corporate governance. At the same time, MNP has begun contributing to working groups and regulatory roundtables, offering strategic legal analysis and industry-informed perspectives to help shape frameworks that are responsive to the needs of businesses while upholding public interest. Bridging Business and Nation-Building This engagement reflects more than just legal cooperation — it is an embodiment of MNP’s deep-rooted belief that law firms have a responsibility to contribute to nation-building, not just commercial success. “For us, this isn’t just about supporting individual entrepreneurs or advising on regulations,” added Arip Sapta, Senior Associate at MNP. “It’s about being a long-term partner in Indonesia’s journey — ensuring that legal infrastructure evolves in a way that is inclusive, strategic, and aligned with the country’s development goals.” MNP has long positioned itself as a trusted advisor to businesses navigating Indonesia’s regulatory terrain. With this MoU, the firm demonstrates its broader commitment to contributing directly to Indonesia’s national progress — acting as a bridge between public policy, legal certainty, and private sector innovation. Looking Ahead As Indonesia continues to rise on the global economic stage, forward-thinking regulatory reform and entrepreneurial resilience will be essential pillars of growth. Murzal & Partners is proud to stand at the forefront of these efforts, working hand-in-hand with the Ministry of Manpower to lay a strong legal and regulatory foundation for the future. About Murzal & Partners (MNP) Murzal & Partners (MNP) is a trusted Indonesian law firm specializing in corporate and commercial transactions, foreign investment, business licensing, capital markets, restructuring, and immigration. Backed by a team of dynamic and industry-savvy lawyers, we provide practical legal solutions tailored to Indonesia’s evolving regulatory landscape. With a strong focus on corporate advisory, litigation, and immigration, we help clients navigate the country’s unique legal and business environment. MNP is also ISO 27001:2013 certified, ensuring the highest standards in client confidentiality and information security. For more information about the firm and to make an inquiry about our legal services, drop an email to [email protected] or visit www.murzallawfirm.com.

Murzal & Partners (MNP), a preeminent Indonesian law firm distinguished for its expertise in immigration law, corporate affairs, and commercial transactions, proudly announces the opening of its new office on Sunset Road, Bali. This expansion marks a significant milestone following a year of exceptional accomplishments, including recognition from Legal500 and the ALB Indonesia Law Awards 2024. Guided by a commitment to delivering bespoke legal solutions, MNP has earned a reputation for its innovative and strategic approach. The firm’s core competencies span general corporate matters, foreign direct investment, commercial transactions, business licensing, and immigration services. With a deep understanding of Indonesia’s complex regulatory landscape, MNP offers clients pragmatic solutions tailored to their specific needs. The establishment of the Bali office underscores MNP’s recognition of the island’s flourishing expatriate community and dynamic business environment. This strategic initiative reinforces the firm’s dedication to providing world-class legal services designed to address the multifaceted requirements of expatriates and enterprises in Bali. “Our expansion to Bali is a testament to our unwavering mission to serve as a trusted partner for our clients,” stated Jufrian Murzal, Founder and Managing Partner of MNP. “This significant development, made possible by the enduring trust of our clients, allows us to bring our tailored services closer to their operations. We remain steadfast in our commitment to delivering incisive legal solutions, empowering businesses and individuals to navigate Indonesia’s legal landscape with confidence and clarity.” As a pioneer in the field of immigration law, MNP is adept at addressing the intricate legal requirements of high-profile corporations and individuals. The firm’s comprehensive offerings include visa and work permit applications, as well as tailored advice to support expatriates in establishing and maintaining residency and business activities in Indonesia. In addition to immigration services, MNP provides integrated corporate legal solutions, covering transactional support, regulatory compliance, and business licensing. The firm’s dedication to confidentiality and data security, exemplified by its ISO 27001 certification, underscores its commitment to the highest professional standards. Murzal & Partners welcomes expatriates, entrepreneurs, and fellow legal professionals in Bali to engage with the firm for sophisticated legal counsel and strategic guidance.  

Makarim & Taira S. is pleased to announce the appointment of Rudy Andreas S. as its newest partner, effective 1 October 2024. Rudy has been with the firm since 2013, following five years of experience at another law firm since 2008, starting as an associate and advancing through the ranks due to his contributions in Litigation, Arbitration & Dispute Resolution, Insolvency & Restructuring, Corporate Governance & Compliance and Employment. Over the years, he has also expanded his expertise to include compliance and criminal litigation, representing numerous Indonesian and foreign companies in high-profile cases and consistently achieving positive results for his clients. Makarim & Taira S.’s Managing Partner, Maria Sagrado, warmly welcomed Rudy’s promotion by saying, “Working alongside Rudy for over a decade, I have always been impressed by his ability to deliver results, his strategic hands-on approach to his work, and his commitment to go the extra mile for our clients. His promotion to partner is a testament to his talent and competence.” Rudy has been recognized by his peers and clients alike, having been named a Rising Star by the Legal 500 Asia-Pacific (2022–2024) and an Up-and-Coming Future Legal Leader by Asia Business Law Journal (2022). Clients consistently praise his prompt and clear guidance, which has led to favorable outcomes in litigation and dispute resolution. In addition to his daily practice, Rudy regularly contributes to legal publications, focusing on litigation and arbitration, and actively shares his insights with the legal community and junior lawyers. With his appointment, Makarim & Taira S. looks forward to Rudy’s continued contributions to the firm’s dispute resolution practice and his ongoing efforts to provide clients with top-tier legal representation and advice.  

The Financial Services Authority of Indonesia (Otoritas Jasa Keuangan, or “OJK”), has introduced Regulation No. 12 of 2024 on the Implementation of Anti-Fraud Strategies by Financial Services Institutions (“Regulation 12/2024”), a consolidated legal framework aimed at combating fraud in the financial services industry. This regulation represents a significant shift in the anti-fraud landscape by consolidating previous regulations and expanding their scope to protect the public, and the institutions themselves ultimately. This article delves into the specifics of Regulation 12/2024, focusing on its implications for financial institutions in Indonesia, the expanded scope of fraud, and the reporting obligations imposed on these entities. Additionally, it highlights the key reporting deadlines and timeframes that LJKs must adhere to, providing critical insights for legal practitioners and compliance officers in the financial sector. Overview of Regulation 12/2024 Regulation 12/2024 has been enacted to streamline and enhance the anti-fraud measures within Indonesia's financial services industry. The regulation mandates that all Financial Services Institutions (Lembaga Jasa Keuangan, or “LJKs”)[1] and other Financial Services Institutions[2] develop and implement comprehensive Anti-Fraud Strategies, designed to prevent, detect, and respond to fraudulent activities. These strategies must consider past fraud incidents and the unique risks inherent to each institution. Regulation 12/2024 shall become effective 3 (three) months from its promulgation on July 31, 2024. Scope of Fraud One of the key features of Regulation 12/2024 is the expanded definition of fraud, which now encompasses a broader range of activities compared to previous regulations. The table below summarizes the acts classified as fraud under Regulation 12/2024: Type Description Corruption Acts such as conflicts of interest, bribery, unauthorized receipt, and extortion that harm LJKs or Consumers. Misuse of Assets Includes misuse of cash, inventory, or other assets, leading to losses for LJKs or other parties. Fraudulent Financial Statement Deliberate misrepresentation in financial statements to benefit fraud perpetrators or harm others. Fraudulence Manipulation or deception related to LJK products or services to benefit oneself or others unlawfully. Leakage of Confidential Information Unlawful distribution of LJK or other parties' confidential information, causing harm or benefiting unauthorized parties.   Anti-Fraud Strategies LJKs are mandated to prepare and implement an Anti-Fraud Strategy, as outlined in Article 3 of the Regulation. The LJKs’ Board of Directors (“BOD”) and Board of Commissioners (“BOC”) are responsible for ensuring the effective implementation of this strategy. This strategy must address the four pillars of Anti-Fraud Strategies namely: prevention; detection; investigation, reporting, and sanction; and monitoring, evaluation, and follow-up of fraud incidents. The regulations governing anti-fraud strategies and risk management for LJKs are primarily outlined in POJK 18/POJK.03/2016 for Commercial Banks and POJK 44/POJK.05/2020 for Non-Bank Financial Services Institutions. Both regulations assign responsibilities to the BOD, including the formulation of written, comprehensive risk management policies, oversight of their implementation, and periodic reviews. The BOD is responsible for ensuring that risk management functions operate independently and that the bank or financial institution maintains adequate resources for risk management. In cases where institutions outsource their Anti-Fraud Strategies to third-party companies or consultancy firms, they must adhere to POJK 9/POJK.03/2016, which stipulates that banks remain accountable for outsourced work and must ensure compliance with regulations through formal agreements. Furthermore, institutions must ensure that corrective actions and updates are made to reports on fraud incidents as mandated in Article 18 of Regulation 12/2024. Therefore, outsourcing is permitted for anti-fraud strategies, provided that institutions maintain compliance with regulatory oversight and reporting obligations. 4.1 Reporting Obligations Regulation 12/2024 imposes stringent reporting obligations on LJKs. These obligations are categorized into three main types of reports: Anti-Fraud Strategies: LJKs must submit a comprehensive document outlining their Anti-Fraud Strategies within a specified timeframe. Anti-Fraud Strategy Implementation Reports: These reports, which detail the implementation of Anti-Fraud Strategies, must be submitted periodically. Reports on Acts of Fraud with Significant Impact: LJKs are required to report any fraud that has a significant impact on their operations. 4.2 Reporting Deadlines The reporting deadlines for these obligations vary depending on the type of LJK: LJK Type Initial Anti-Fraud Strategy Report Anti-Fraud Strategy Implementation Report Deadline Fraud Incident Report Deadline Commercial Banks and Financing Companies 3 (three) months from the enactment of Regulation 12/2024. Every semester (June and December). Within 3 (three) business days of discovery. Other Financial Institutions 6 (six) months from the enactment of Regulation 12/2024. Annually (by January 31st of the following year). Within 6 (six) business days of discovery.  4.3 Content of Reports In addition to meeting specific deadlines, LJKs must ensure that the Anti-Fraud Strategy Implementation Reports and Reports on Acts of Fraud with Significant Impact must include the following details: name of the LJK; the identity and position of the fraud perpetrators; the type and modus operandi of the fraud; the affected division; the time and location of the incident; andand the amount of loss incurred. Sanctions for Non-Compliance To ensure compliance, the regulation includes stringent penalties for LJKs that fail to implement or report on their anti-fraud strategies: Violation Penalty Late submission of anti-fraud strategy Fines ranging from IDR 50,000 to IDR 1,500,000 per day, depending on the type of LJK. Incorrect information in reports Fines ranging from IDR 10,000 to IDR 50,000 per incorrect entry, with maximum penalties capped. Repeated violations Escalation to suspension of activities or prohibition of new products.   Implications for LJKs The implementation of Regulation 12/2024 has significant implications for all financial services institutions in Indonesia. LJKs must invest in internal control systems and ensure that their anti-fraud strategies are not only compliant with the regulation but also effective in mitigating risks. Key challenges include: Resource Allocation: LJKs, especially smaller institutions, may face challenges in allocating resources to develop and maintain comprehensive anti-fraud systems. Training and Awareness: Ensuring that employees are adequately trained and aware of the anti-fraud policies is critical for the effectiveness of these strategies. Reporting and Documentation: LJKs must establish clear processes for documenting and reporting fraud incidents to comply with OJK requirements. Key Takeaways For legal practitioners and compliance officers, it is essential to understand the expanded scope of fraud, the specific reporting obligations, and the strict deadlines outlined in this regulation. Ensuring that all reporting requirements are met in a timely and accurate manner will be crucial to avoiding potential sanctions and maintaining the integrity of the financial services industry. Regulation 12/2024 represents a critical step forward in Indonesia's efforts to combat fraud within the financial services industry. By consolidating and standardizing anti-fraud strategies across a wide range of financial institutions, the regulation not only simplifies compliance but also strengthens the industry's defences against fraud. Footnotes [1] Defined as “institutions that carry out activities in the sectors of banking, capital markets, insurance, pension funds, venture capital, microfinance institutions, financing institutions, and other financial services institutions.” [2] Defined as “pawnshops, guarantee institutions, the Indonesian export financing institution, secondary housing financing company, organizers of information technology-based joint funding services, and institutions that organize mandatory public fund management, including organizers of social security, pension, and welfare programs, as referred to in the laws and regulations on pawnshops, guarantees, the Indonesian export financing institution, secondary housing financing company, and mandatory public fund management, as well as other financial services institutions that are declared to be supervised by the Financial Services Authority based on the provisions of laws and regulations.”