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Selective Overview on SEOJK No. 6 of 2021: Non-Face-to-Face verification, Pre-Employee Screening and Example of Suspicious Financial Transaction

Author: Joshua Juanputra, Fatih Al-Rosyid, Tue, Mar 2nd 2021, 15:56

SEOJK no. 6 year 2021 concerning the Implementation Guidelines of Anti Money Laundering and Prevention of Terrorism Financing Program within Technology-Based Fund Lending Services (“SEOJK 6/2021”) is the implementation regulation to POJK 12/2017 concerning Implementation of Anti Money Laundering and Anti-Terrorism Financing in Financial Service Sectors. SEOJK 6/2021 specifically regulates Anti-Money Laundering (“AML”) and Anti-Terrorism Financing (“ATF”) in Peer-to-Peer Lending (“P2PL”).

This overview will be focusing on key implementation provisions most relevant to P2PL particularly Non-Face-to-Face verification, Pre-Employee Screening and Example of Suspicious Financial Transaction in P2PL Platform. These key aspects that distinct AML and ATF in P2PL with the Bank.

Non-Face-to-Face Verification

SEOJK 6/2021 set standardization for P2PL platform to standardize its approach to verify its customers. It is possible for non-face-to-face verification to be carried out, ensuring that: The candidate Lender/Borrower devices are equipped with identification support.

Employee Screening, Identification and Monitoring

SEOJK 6/2021 set the obligation for P2PL platform to perform a pre-employee screening to any candidate, such as the requirement of police record letter (SKCK), face-to-face interview or a non-face-to-face interview. Implementing such methods will help to ensure the credibility of employee and their responsibilities to high-risk activities such as access to database or dealing with Lender/Borrower.


armila rako SEOJK 6 2021 law firm south jakarta selatan

Please contact Joshua Juanputra or Fatih Al-Rosyid for any inquiries regarding SEOJK 6/2021.


Armila & Rako is a law firm in South Jakarta that provides a comprehensive range of legal and professional services for clients of both local and international. Our clients include public and privately-held companies, large and emerging businesses, as well as public sector entities. While we focus and corporate and commercial matters, the principal industries we represent include energy, mining, electricity, oil and gas, plantation and forestry, infrastructure, financial technology, consumer products as well as other manufacturing industries.