Implementation of Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Counter Proliferation Financing of Waepons of Mass Destruction (CPF) Program

PT BFI Finance Indonesia Tbk (BFI Finance) is committed to implement Anti-Money Laundering, Combating the Financing of Terrorism, and Counter Proliferation Financing of Weapons of Mass Destruction (AML-CFT-CPF) Program in accordance with the prevailing laws, namely:

• Law of the Republic of Indonesia Number 8 Year 2010 concerning Prevention and Eradication of Money Laundering Crime.
• Law of the Republic of Indonesia Number 9 Year 2013 concerning Prevention and Eradication of Financing of Terrorism Crime.
• OJK Regulation Number 8/POJK.01/2023 concerning Implementation of Anti-Money Laundering, Combating the Financing of Terrorism, and Counter Proliferation Financing of Weapons of Mass Destruction Program in Financial Services Sector.
• OJK Circular Letter Number 37/SEOJK.05/2017 concerning Guidelines for Implementation of Anti-Money Laundering and Countering Financing of Terrorism Program in Non-Bank Financial Industry Sector.

Implementation of AML-CFT-CPF of BFI Finance, which encompasses:

1. Active Supervision by the BOD and the BOC 
   1. Discussion of the AML-CFT-CPF framework and necessary follow-up actions, considering all regulatory requirements and the Company’s strategy; and
   2. Update to the AML—CFT—CPF risk profile calculation reference, based on the latest National Risk Assessment (NRA) issued by PPATK and the Sectoral Risk Assessment (SRA) issued by the OJK.
2. Policies and Procedures
   1. Adjustment of employee and partner recruitment policies, as well as debtor acceptance policies, by adding filters for individuals associated with online gambling;
   2. Dissemination of policies and procedures related to the implementation of AML—CFT—CPF program in each function in the Company; and
   3. Reporting of Cash Transactions and Suspicious Transactions to PPATK through the GoAML application.
3. Internal Control 
   1. Collaboration with Internal Audit in the audit of policies and procedures in accordance with POJK 8/2023 as well as auditing the implementation of the Company AML-CFT-CPF policies and procedures; and
   2. Data Updating program, for which the plans and accomplishments have been reported to OJK.
4. Management Information System
   1. Quarterly reporting of debtors’ data to PPATK through the SIPESAT application;
   2. Identification and implementation of AML-CFT-CPF “red flag tools” in accordance with the Circular of the Head of PPATK No. SE-03/1.02/PPATK/05/15 on the Indicators of Suspicious Financial Transactions for Financial Services Provider, for monitoring of Cash Transactions and Suspicious Transactions;
   3. Testing of the strength of indicators in AML-CFT-CPF “red flag tools” to ensure that the Company is not utilized as a means of money laundering;
   4. Monitoring of Cash Transactions and Suspicious Transactions on a regular basis to ensure that no cash transactions whose value exceeded Rp500 million were reported late;
   5. Creating a Watchlist Database related to the implementation of AML-CFT-CPF Program from various data sources that are not only oriented towards domestic regulatory compliance, but also the interests of investors from the European Union and the United States to identify the level of risk of Debtors and Prospective Debtors;
   6. Enrichment of the Politically Exposed Persons (PEPs) Database by drawing on various sources; 
   7. Classification of SIPENDAR Database into the Sanctions Lists Database as part of debtor screening process prior to issuance of financing contract, using the Check and Validation (CNV) application;
   8. Reporting of enrichment of information on parties suspected of terrorism financing through the SIPENDAR application; and
   9. Reporting of AML—CFT—CPF risk scoring level through OJK’s Online Reporting Application (APOLO).
5. Human Resources and Training
   1. The Company’s human capital training and monitoring on AML-CFT-CPF was conducted via M-BEAT application (digital learning media for BFI Finance’s employees); 
   2. Participation in AML—CFT—CPF seminars and trainings from OJK, PPATK, and other parties, to ensure understanding and knowledge in line with the latest regulatory developments and typologies of money laundering, terrorism financing, and financing for the proliferation of weapons of mass destruction;
   3. Training for employees in the positions of Credit Factory Head, Credit Commercial Analyst, Credit PBF, Sharia & Non-Collateral Credit as well as the Credit Operations Team at the head office as the parties responsible for AML-CFT-CPF on the updates regarding the implementation of POJK 8/2023 and AML-CFT-CPF cases in multifinance companies;
   4. Updates to the employee recruitment process using the AML-CFT-CPF Watchlist as a preventive measure so that the Company avoids personnel who may be able to abuse the Company as a means of operating crimes; and
   5. The issuance of provisions regarding Know Your Employee as a measure to anticipate and prevent fraud in the Company by detecting and identifying employees who have the potential to commit violations and have legal vulnerabilities.