09 Feb 2026
ABNR Shares Insights with OJK on KUHAP 2025 and Its Potential Impact on Criminal Investigation in the Financial Services Sector

As Indonesia's new Criminal Procedure Code (KUHAP 2025) reshapes the landscape of criminal investigation and enforcement in the financial services sector, ABNR recently had the opportunity to share insights with the Otoritas Jasa Keuangan (OJK) on the reform's key implications. At OJK's invitation, ABNR contributed to an internal Sharing Session held on 30 January 2026, where Rosevelt Riedel Lontoh (Partner) and Sulaiman Khosyi Suharto (Associate) delivered a presentation titled “Membaca Arah Baru Proses Pidana: Implikasi KUHAP Baru di Sektor Jasa Keuangan,” with the session also attended by Ayik Candrawulan Gunadi (Partner).

The session reviewed the major reforms introduced under KUHAP 2025, which has been in effect since early January 2026, and highlighted their implications for OJK’s investigative and supervisory functions in the financial services sector. Key points included introduction to the restorative justice arrangement, plea bargain and deferred prosecution agreement, the strengthened legal basis for electronic evidence, clearer procedures governing corporate criminal liability, expanded pre‑trial (praperadilan) authority and its associated risks, and enhanced administrative and procedural standards for investigations.

The discussion also emphasized the importance of structured coordination between OJK’s investigators and the Indonesian National Police, including regarding the execution of coercive measures such as seizure, search, or account blocking. The shift in orientation from a primarily punitive model toward a more restorative and preventive criminal‑justice approach was also highlighted for its relevance to OJK’s future enforcement strategies.

For ABNR, the session provided valuable insight into regulatory expectations, priorities, and operational challenges related to KUHAP 2025. These insights strengthen the firm’s ability to advise clients navigating matters at the intersection of financial regulation, corporate compliance, and administrative‑criminal enforcement.

ABNR extends its thanks to OJK’s Internal Audit and Risk Management Division, as well as Ms. Sophia Isabella Wattimena (Chair of the OJK Audit Board and OJK Commissioner), Mr. Djonieri (Deputy Commissioner for Internal Audit, Risk Management, and Quality Control), and the participating Directors and team members for their thoughtful engagement and open exchange of views.

ABNR remains committed to constructive engagement with regulators on key legal and regulatory developments impacting Indonesia's financial services sector. Special thanks to our ABNR Team members, Rafie Agassi Usman (Associate) and Farid Indraputra (Trainee Associate), for their support during preparation and throughout the session.

For further discussion on KUHAP 2025's implications for your business, please contact info@abnrlaw.com.