Based on these findings it was concluded that, overall Indonesia is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to validation of files with the CRS XML Schema requirements. Indonesia is therefore encouraged to continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Indonesia should continue to address the issue raised by its exchange partner.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Indonesia linked to the CTS
Based on these findings it was concluded that Indonesia is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Indonesia is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Three exchange partners highlighted delays in the sending of information by Indonesia (representing 4% of its partners). This represents a relatively high proportion of exchange partners. However, in two out of those three cases, it is clear that the delay was not highlighted promptly to Indonesia by the affected partners and Indonesia has worked proactively to effectively address all of the issues as soon as possible.
Based on these findings it was concluded that, Indonesia is fully meeting expectations in relation to exchanging the information in a timely manner. Indonesia is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Indonesia’s exchange partners did not raise any concerns with respect to Indonesia’s use of the agreed transmission methods and therefore with Indonesia’s implementation of this requirement.
Based on these findings it was concluded that Indonesia is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Indonesia is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Six exchange partners highlighted delays in the sending of status messages by Indonesia, representing 6% of its partners. This represents a relatively high proportion of partners, although it has improved over time. It was noted that Indonesia appears to be addressing the issues to ensure that status messages are sent in accordance with the requirements.
Based on these findings it was concluded that, overall, Indonesia is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to the sending of timely status messages to the sending jurisdictions. Indonesia is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
Indonesia should ensure it consistently sends timely status messages to the sending jurisdictions when files are received.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Jurisdiction has responded to notifications and provided corrected, amended or additional information in a timely manner. One exchange partner highlighted delays in Indonesia responding to such notifications. It was noted that Indonesia has taken action to address the issue by sending corrected information to its exchange partner.
Based on these findings it was concluded that, overall, Indonesia appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. It was also noted that there is room for improvement with respect to responding to a notification from an exchange partner in a timely manner. Indonesia is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the area highlighted.
Recommendations:
No recommendation made.