Penerapan APU PPT dan PPPSPM The AML/CFT and CFPWMD program at BNI Finance is established through five pillars: Active Supervision by the Board of Commissioners and Board of Directors, Policies and Procedures, Internal Controls, Management Information System, and Human Resources & Training.

1. Active Supervision by the Board of Commissioners and Board of Directors

In support of the implementation of the AML/CFT program, active involvement from the Board of Directors and Board of Commissioners is crucial to ensure the effectiveness of the AML/CFT program implementation. The active role of the Board of Directors and Board of Commissioners is essential as it significantly influences the organization's achievement in implementing the AML/CFT program objectives.
 

The active oversight roles of Directors and Commissioners at PT BNI Multifinance are as follows:

1. The Board of Directors and Board of Commissioners have established Technical and Strategic Policy Procedures related to the implementation of the AML/CFT Program

2. The Board of Directors and Board of Commissioners have established a Special Working Unit for the Implementation of the AML/CFT Program (APU CFT Special Working Unit).

3. The Board of Directors and Board of Commissioners regularly request and receive reports on the implementation of the AML/CFT Program, with reports being routinely submitted every quarter.

4. The Chief Executive Officer overseeing the Compliance function supervises the updating of Customer Data, including approving Customer Data Update Plan Reports and Customer Data Update Implementation Reports.

5. The Board of Directors and Board of Commissioners actively discuss the implementation of AML/CFT in meetings of the Board of Directors and Board of Commissioners (Radikom).

2. Policies and Procedures

All AML/CFT policies have been reviewed in accordance with regulatory changes through POJK No. 8/2023, with approval of all guidelines up to the Board of Commissioners, as follows:

1. Policy on Implementation of AML/CFT and CFPWMD Guidelines

2. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) Procedures

3. Suspicious Financial Transactions and Integrated Governance Procedures

4. AML/CFT and CFPWMD Risk Assessment Procedures

3. Internal Control

1. In monitoring the implementation of the AML/CFT and CFPWMD policies across all units, BNI Multifinance has established the need for assessments and requirements for the implementation of AML/CFT and CFPWMD regarding new business activities and/or products

2. The AML/CFT and CFPWMD Special Working Unit (UKK APU PPT) periodically supervises and coordinates with other units, business units, and branch offices to ensure the implementation of AML/CFT and CFPWMD across all units and branches.

3. Regular internal and external audits are conducted by BNI Multifinance's Internal Audit and by the Parent Company through Bank BNI's Internal Audit Unit (SAI)

4. Management Information System

To support the implementation of AML/CFT and CFPWMD, optimization of system/tools development is carried out to support AML/CFT obligations in accordance with regulations. 

Continuous system development considers changes in AML/CFT and CFPWMD regulations, enabling effective identification, analysis, monitoring, and reporting.

5. Human Resources and Training

In this Pillar, BNI Finance has established procedures for screening/recruitment, introduction and monitoring of employees through the policy of knowing your employee and the policy of block leave. 
 

In addition, another important thing is to improve employee capabilities in understanding the provisions of APU PPT and PPPSPM, especially for employees related to the implementation of APU PPT and PPPSPM, through the implementation of routine and periodic training/socialization and accompanied by the Implementation of an Understanding Test after the socialization is carried out (Post Test) to measure the level of employee understanding of the APU PPT and PPPSPM materials presented. Mandatory Learning / Mandatory Training that must be followed / accessed by employees through the Company's Internal Portal / Company e-Learning Facilities.