4 Reasons Why

2023 Financial
Sector Omnibus
Law,
is Worth Considering
for Your Investment
in Indonesia.
Prepared by Gustaf Joshua & Celine Tangnandez Wijaya (Associates)
Supervised by Ronaldi Reisman (Founding Partner)
What's with this Law?
On 12 January 2023, Law No. 4 on 2023 was issued,
with changes omnibus in nature to sectors related to
finance, hence the name.
These sectors include:
banking;
futures trading;
securities; and
other financing services.
If you’re already an investor or still planning to
invest in Indonesia, in these sectors, the following
should be worth considering.
 one
OJK authorized to
oversee crypto
Fintech now goes by “financial sector technology innovation”.

Crypto is included in it. And OJK will become the supervising authority,
supposedly in July 2023, 6 months after the Law was enacted. It,
however, remains unclear whether it will be just OJK or it plus Bappebti.
Our Bappebti contacts have also confirmed the foregoing.

What this means for crypto? It can mean the government will be taking a
stricter approach toward crypto, by treating it as a form of securities,
rather than commodity.
 two
Fintech Association
Membership Requirements
Fintech companies are now required to become members
associations. These associations should be approved and being
monitored by OJK and BI. They are basically tasked with helping
said authorities develop and monitor their members.

But the Law is unclear on what happens if a fintech sector has

yet to form an association. The Law just says that further
matters will be governed by OJK and BI.
 three
Central bank digital currency
acknowledged!
Finally! CBDC is now a type of currency. With this, CBDC can be
used for transactional purposes. And it will be monitored by BI.

Also, a Ministry of Finance official has clarified that CBDC would be

on a private, rather than public, blockchain. This can mean that
information contained on it will not be pseudonymous like in a public
blockchain, but rather anonymous.

Multiple BI regulations have been mandated by the Law to be issued.

 four
Is the law already
effective?
Yes, it is. Its implementing regulations will be issued in
2 years tops.

Stay tune for our next updates!

Are you interested in knowing more?

IF YOU HAVE
QUESTIONS FOR US,
DROP COMMENTS OR
DM!
This is merely our summary of the legal products mentioned, and cannot be construed or used (partly
or entirely) as our legal opinion, without our prior written consent.
A more comprehensive form of this summary can be made available upon request.
Also, a Bahasa Indonesia version of it, or the more comprehensive form, can be made available upon
request.
Any questions can be directed to the lawyers identified at the beginning, through RSPS’ social media
accounts.