In line with the latest developments related to the AML-CFT program and in connection with the Financial Services Authority Regulation No. 12/POJK.01/2017 concerning the Implementation of the Anti-Money Laundering and Combating the Financing of Terrorism Program in the Financial Services Sector, which among other things regulates the application of the AML-CFT within the Financial Conglomerate, so RS has made improvements to the AML-CFT Program implementation policy, based on 5 ( five) Pillars for AML-CFT Program Implementation, namely :

1. Active supervision of the Board of Commissioners and Directors
2. Policy and Procedure
3. Internal Control
4. Management Information System
5. Human Resources and Training

Improvements to the Policy include:

1. Match the perceptions and understanding of all levels of the management regarding the importance of implementing the APU PP program;
2. Become a guideline in mitigating risks including legal risk, reputation risk, and operational risk;
3. Become a guideline in the preparation of product operational procedures and other activities;
4. Fulfil the provisions in Financial Services Authority Regulation regarding the Implementation of the AML and PPT Program in the Financial Services

In order to increase the effectiveness of the AML-CFT program implementation at RS, it is necessary to support the active supervision of the Board of Commissioners and Directors so that they can motivate employees and work units in establishing a culture of compliance in all levels of the Company. The supervision includes the risk management of AML-CFT in Subsidiaries which is under the coordination of the AML-CFT Special Work Unit.

The implementation of the AML-CFT program is carried out by the AML-CFT Special Work Unit which is structurally under the RS Compliance Unit and is directly responsible to the Director in charge of the compliance function. The AML-CFT Organizational Structure can be described as follows:

RS commitment to implementing the AML-CFT program consistently and effectively implemented in the program includes the following:

1. Integrating the application of the AML-CFT program in the Financial Conglomerate through the establishment of AML-CFT policies and procedures.
2. Application of the AML-CFT program in the Financial Conglomerate through the formulation of policies and procedures related to the exchange of information for the purpose of Customer Due Diligence and risk management.
3. Increasing the compliance culture in the implementation of the AML-CFT program which was followed up with efforts to improve the operational quality.
4. Establishing and fostering cooperation and coordination with Regulators and law enforcers, especially in the field of AML-CFT through the provision of customer data/information that has been determined as a suspect or subject of
5. Preparation of renewal of the risk assessment methodology based on the Risk Based Approach by taking into account the factors related to the Customer; Country or Geographic Area; Products, Services or Transactions; and/or Distribution Channel (Delivery Channel).
6. Establishing and fostering cooperation with data provider units in fulfilling customer data and transaction information for the purpose of analyzing customer
7. Improving the quality and monitoring of reporting of Cash Transaction Reports, Fund Transfers and Foreign Transactions Financial Transaction Reports, Suspicious Financial Transaction Reports, and Integrated Service User Information Systems without exceeding Service Level Agreement (SLA) determined by the Regulator.
8. Perfecting the Reporting Application System and AML-CFT which includes, among other things, improving the appearance of the Report, adding Transaction Codes monitored by the transaction, adding Watch-lists from the List of Suspected Terrorists and Terrorist Organizations, List of Proliferation Funds for Weapons of Mass Destruction and List of Negative Information sourced from Mass Media on AML
9. Providing supporting data for the Company’s operational activities in the form of customer classification according to the risks and providing data on the opponent’s account
10. Increasing awareness of AML-CFT for employees at all levels of the organization through AML- CFT training with several media namely classroom training, e-learning and socialization to all employees of RS.