More and more financial institutions in Indonesia have recently been implementing and certifying an Anti-Bribery Management System (ABMS) based on ISO 37001. Many people ask: is this really mandatory, or just a voluntary initiative by individual companies? This article summarizes the regulator’s position and the sectors most affected.
Regulatory push toward the financial services sector
The Financial Services Authority (OJK), as the regulator of Indonesia’s financial services sector, actively encourages the implementation of anti-corruption and anti-bribery governance at the institutions it supervises. Several financial institutions, including those under OJK’s supervision, have implemented and maintained SNI ISO 37001 ABMS certification through routine surveillance as part of their commitment to good corporate governance.
Although its implementation has not yet taken the form of a uniform legal obligation for all types of financial institutions, the regulatory trend and supervisory expectations point in a clear direction: anti-bribery certification based on ISO 37001 is becoming one of the compliance indicators increasingly taken into account, especially for large-scale institutions or those with high exposure to bribery risk (for example, in procurement processes, third-party partnerships, or licensing).
Which sectors are most affected?
- Banking – credit processes, procurement, and vendor partnerships are vulnerable to bribery risk.
- Financing and multifinance companies – financing approval processes and dealer partnerships.
- Insurance – claims processes and partnerships with agents/brokers.
- Pension funds and investment management institutions – asset management and partnerships with third-party investment managers.
Why financial institutions should not wait until it is truly mandatory
Regardless of its mandatory status, there are several practical reasons why financial institutions are increasingly proactive in implementing ISO 37001:
- It becomes an added value in governance assessments by regulators and business partners.
- It reduces reputational and legal risk from bribery cases involving employees or third parties.
- It strengthens customer and investor trust in the institution’s integrity.
- It is increasingly becoming a requirement for partnerships with other institutions, including state-owned enterprises and government agencies.
First steps toward certification
For financial institutions wanting to start implementing ISO 37001, the first step is usually a bribery risk assessment of the most vulnerable business processes, followed by drafting an anti-bribery policy and appointing a compliance function. After the system has been running for a few months, the organization can apply for a certification audit with an accredited certification body such as Sertifin. Also read our article on estimated ISO 37001 certification cost for budget planning purposes.