New Country Manual Products
Indonesia – BRP 2024
BRP has updated its Country Manual Products for Indonesia
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Definitions & Concepts, Regulatory Overview and Behaviour Template
The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.
Material changes
The main changes/modifications are as follows:
- In alignment with the Country Manual Private Banking (CM PB), the provision of macroeconomic information/reports and investment research/financial analysis is now only permitted on a one-to-one and occasional basis onshore in Indonesia (at target). Accordingly, the Country Manual Products Behaviour Template (CM P BT) answers this scenario with “Grey zone/YES”.
- It is further highlighted that the provision of investment services as well as any marketing activities (other than the provision of either macroeconomic information/reports or investment research/financial analysis) are not permitted onshore in Indonesia (at target) without an appropriate licence. The CM P BT therefore now gives the answer “NO” for all relevant onshore scenarios.
- Based on advice from our local counsel, the “local distribution rules” of Indonesia do not need to be considered for offshore activities (at source), provided that the investor has not been induced/encouraged to leave Indonesia in order to receive the relevant product-related service and provided that no marketing material has been sent to Indonesia prior to the visit and all funds/assets are booked offshore.
- Please note that any activity, either at the initiative of the service provider or at the request of the client in relation to locally registered financial products must (in all scenarios) be executed through a duly licensed local Securities Company. Therefore, only foreign (unregistered) financial products can now be distributed in accordance with the “current market practice” (as described in the CM P Regulatory Overview (CM P RO)).
For more information, please contact us: info@brpsa.com
Geneva, June 21st, 2024