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Regulatory Sandbox for Fintech Operators in Indonesia

Introduction

Digital Financial Innovation/Inovasi Keuangan Digital (“IKD”) also known as technological innovation in the financial sector among others include aggregators, credit scoring, financing agent, transaction authentication, financial planner, electronic–know–your–customer (E-KYC), reg-tech-eSign, etc., have experienced rapid advancements. However, it is crucial to mitigate the disruptive effects of digital technology to maintain stability in a country’s financial system, economy, and consumer personal data protection.

To address this, the Financial Services Authority (OJK) has implemented measures to mitigate the risks associated with IKD. The Financial Services Authority/Otoritas Jasa Keuangan (“OJK”) has issued the OJK Regulation Number 13/POJK.02/2018 of 2018, which focuses on Digital Financial Innovation in the Financial Services Sector (“POJK 13/2018”). These regulations aim to create a controlled environment for testing new financial technologies while minimizing potential disruptions to the financial system and economy with a maximum trial period of 1 year and 6 months.

Overview of OJK’s Regulatory Sandbox

Based on PADG 19/2017, a Regulatory Sandbox is defined as a limited safe trial space to test Financial Technology Operators and their products, services, technology, and/or business models. Meanwhile, according to Article 1 of POJK 13/2018, Regulatory Sandbox is a testing mechanism carried out by the OJK to assess the reliability of business processes, business models, financial instruments, and governance of the Operator.

So, it can be understood that the Regulatory Sandbox is a selection process by the competent authority for the concept of technological innovation in the financial sector to be offered by a fintech which must fulfill certain requirements and compliances during the specified period.

Implementation of OJK’s Regulatory Sandbox

Implementation of Regulatory Sandbox by OJK is carried out for IKD Operators. IKD Operators in question are Financial Services Institutions that have financial service activities in the banking sector, capital market, insurance, pension funds, financing, and other financial institutions. [1] IKD must be innovative and use information technology as the main means of providing financial services to consumers. By Article 4 POJK 13/2018, the implementation of a regulatory sandbox under the OJK is carried out to ensure that all IKD operators meet the following criteria:[2]

– Be innovative and future-oriented;
– Using information and communication technology as the main means of providing services to consumers in the financial services sector;
– Supporting financial inclusion and literacy;
– Useful and can be used widely;
– Can be integrated into existing financial services;
– Using a collaborative approach; and
– Take into account the aspects of consumer protection and data protection.

a. To be registered as IKD, Operators at least fulfill the following requirements:

be registered as IKDs within the Financial Services Authority or based on an application submitted by the relevant supervisory working unit at the Financial Services Authority;
– are a new business model;
– has a business scale with a wide coverage of the market;
– be registered at an association of Operators; and
– other criteria set out by the Financial Services Authority.

b. Implementation of the Regulatory Sandbox under OJK is carried out within a maximum period of 1 (one) year and can be extended for 6 (six) months if necessary. [3]

Result of Implementation of OJK’s Regulatory Sandbox

The results of the implementation of the Regulatory Sandbox by the OJK for the Operators will be stated with the following status: [4]

Recommended:

IKD Operator with recommended status will be given a recommendation for registration by OJK. Such Operators must submit an application for registration to the OJK no later than 6 (six) months after the recommendation status is determined, or the registration recommendation status will be revoked and declared invalid;

Need Improvement:

For operators with repair status, OJK can give time for the Operator to make improvements no later than 6 (six) months from the date of determination; or

Not Recommended:

If the status results are not recommended, the Operator cannot re-submit the same IKD and is removed from the record as the Operator.

Conclusion:

Regulatory Sandbox issued by OJK serves multiple purposes, not only as a policy supporting fintech innovation and future readiness but also as a means of safeguarding consumers and the broader community. It not only enhances user trust and confidence but also acts as a magnet for investors seeking investment opportunities.

[1] Article 1 number 2 POJK 13/2018

[2] Article 2 POJK 13/2018

[3] Article 9 POJK 13/2018

[4] Article 11 – 14 POJK 13/2018

Sources:

– Regulation of Members of the Board of Governors Number: 19/14/PADG/2017 of 2017 concerning the Limited Technology Testing Room (Regulatory Sandbox) Financial Technology
– Regulation of The Financial Services Authority of The Republic Of Indonesia Number 13/POJK.02/2018 of 2018 concerning Digital Financial Innovations Within The Financial Services Sector

This article has been contributed by Jodi Hizkia Hutagalung of Armila Rako, a corporate law firm based in Jakarta. The above article does not, and is not intended to, constitute legal advice; instead, this article is for general informational purposes only. Information contained in this article may not constitute the most up-to-date legal or other information. Should the readers have any inquiries, readers can contact the authors at jodi.hizkia@armilarako.com Any reliance on this article is at the user’s own risk.

Overview of the New Indonesia-Singapore Bilateral Investment Treaty

On 9 March 2021, the latest Singapore-Indonesia Bilateral Investment Treaty (the “BIT“) entered into force and updates the countries’ investment protection framework vis-a-vis each other. This BIT was previously signed on 11 October 2018 with the goal of promoting stronger economic ties and cooperation between the countries, and replaces the previous Singapore-Indonesia Bilateral Investment Treaty which had entered into force on 21 June 2006 and expired on 20 June 2016 (the “Previous BIT“).

Singapore and Indonesia have historically maintained strong trade ties with each other. Despite trade disruptions brought about by the COVID-19 pandemic, Singapore was Indonesia’s largest foreign investor in 2020, with investments totalling USD 9.8 billion; the countries also enjoyed strong bilateral trade in 2020 of approximately USD 36.8 billion.

Updates to Singapore-Indonesia investment provisions

We summarise some of the more salient updates to the Singapore-Indonesia investment provisions below (where applicable, Singapore and Indonesia will hereafter each be referred to as a “State“):

  • Broadened express definition of “investment”: Whilst the categories of assets which qualify as an “investment” are not closed, the express definition of assets which fall within the meaning of “investment” for purposes of the BIT has been broadened. In particular, the express definition now explicitly includes inter alia construction, production or revenue-sharing contracts, licences, authorisations, permits and similar rights conferred pursuant to the applicable domestic law, and other tangible or intangible property. However, the overarching requirement is that such assets must have the characteristics of an investment.
  • Most-Favoured-Nation Treatment Clause: Article 5 of the BIT (i.e. the Most-Favoured Nation Treatment clause) clarifies that its provisions will not be construed to oblige a State to extend to the investors of the other State benefits of any treatment, preference or privilege from bilateral investment agreements that were initialled, signed or entered into force prior to the entry into force of the BIT, or geographical arrangements within the framework of specific projects. Article 5 also clarifies that it does not apply to options or procedures for the settlement of disputes available in other agreements, and substantive obligations in other international investment treaties or trade agreements do not themselves constitute “treatment” and will not give rise to a breach of Article 5 per se.
  • Restrictions on transfer of assets: Article 8 of the BIT now clarifies circumstances in which a State may prevent an investor’s transfer of assets out of said State through the equitable, non-discriminatory and good faith application of its laws relating to inter alia, bankruptcy, insolvency or the protection of creditors’ rights; dealing in securities, futures, options or derivatives; criminal or penal offences; financial reporting or record keeping as necessary to assist the authorities; ensuring compliance with judicial and administrative orders or proceedings; or severance entitlements for employees. Article 9 of the BIT also provides that a State may in exceptional circumstances, impose reasonable and non-discriminatory restrictions on the transfer of assets or capital.
  • Right to regulate: Article 11 of the BIT sets out expressly the States’ right to regulate within their respective territories to achieve legitimate policy objectives, and clarifies that the mere fact that a State regulates, including through modification of its laws, in a manner which negatively affects an investment or interferes with an investor’s expectations, will not amount to a breach of an obligation under the BIT.
  • Longer pre-arbitration consultation period between disputing investor and State: Article 17 of the BIT provides for a 1 year consultation period (or recourse to mediation processes) before the investor may submit the dispute to arbitration or relevant national court, this consultation period was 6 months in the Previous BIT.

Comparison with previous generation of investment treaties

The above updates to the investment protection framework between Singapore and Indonesia must be seen in context, and it would be apposite to examine the language of the BIT’s articles in light of key characteristics of other investment-related treaties concluded recently in the region.

The Regional Comprehensive Economic Partnership Agreement (“RCEP“) and the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (“CPTPP“) are similar to the BIT in being modern treaties promoting regional economic partnerships, containing investment protection provisions. The RCEP was signed on 15 March 2020, whereas the CPTPP was signed on 8 March 2018 and entered into force on 30 December 2018.

An examination of the BIT, the RCEP’s investment provisions and the CPTPP’s investment provisions makes clear that these treaties are part of a new generation of investment treaties which rebalances and recalibrates rights and obligations vis-à-vis contracting States and investors. This has been done by inter alia expressly carving out sufficient regulatory space for the host State through express language of investment provisions, and drafting said treaties with the intent of ensuring that tribunals do not interpret investment protection provisions beyond the scope of what contracting States had intended.

In relation to the BIT’s investment provisions specifically:

  • Sufficient regulatory space for the host State: Article 8(3) allows a host State to restrict investors’ transfer of capital into and out of its territory in connection with legitimate regulatory purposes, and Article 9 allows a host State to impose calibrated restrictions in exceptional circumstances where said transfer may cause serious difficulties for the State’s macroeconomic management. Most pertinently, Article 11 expressly provides for a State’s right to regulate, and clarifies that a State’s regulatory acts do not amount to a breach of the BIT’s obligations per se. Such provisions were uncommon in previous generations of investment treaties.
  • Preventing investment protection provisions from being interpreted too widely: It is apparent that the BIT was drafted with the objective of ensuring that tribunals do not interpret its Articles beyond the scope of what contracting States intended. In this connection, the draftsmen of the BIT have drawn lessons from tribunals’ interpretation of previous generations of investment treaty terms to significantly narrow the scope of interpretative uncertainty in the BIT. For example, the BIT curtails the scope of its Most-Favoured-Nation Treatment clause (Article 5) by expressly providing that it does not apply to dispute resolution procedures and substantive obligations in other agreements. In the same vein, the language of the BIT (Articles 3(2) and 3(3)) expressly clarifies what the BIT means by “fair and equitable treatment” and “full protection and security”, in attempts to foreclose the possibility of such provisions being interpreted in an excessively wide manner (as had notoriously been the case for previous generations of investment treaties).

Concluding observations

The BIT serves as a prime modern example of investment treaties which seek to rebalance the distribution of rights between host States and investors, whilst retaining familiar investor State dispute settlement mechanisms which provides for recourse to ad hoc tribunals. This stands in contrast to the other strand of modern investment treaties, which adopts the more drastic approach of doing away with (or phasing out) traditional investor State dispute settlement mechanisms in favour of a public investment court system (e.g. Chapter 8 of the Comprehensive and Economic Trade Agreement). Only time can tell which approach will set the standard for the next generation of investment treaties.

W&C Advises on Telecommunication PPP Project in Indonesia

Global law firm White & Case LLP and exclusive Indonesian association law firm Witara Cakra Advocates (WCA) have advised the lenders on the financing of the US$540 million Indonesia Government Multifunction Satellite Public Private Partnership (PPP) Project.

“This exciting project will harness satellite-based connectivity to bring significant social and economic benefits to remote parts of Indonesia,” said White & Case partner Mukund Dhar, who co-led the Firm’s deal team. “It is a unique transaction which demonstrates the cross-border experience and cross practice capabilities our clients rely on us for when financing first-of-their kind major satellites in the telecommunications sector.”

Indonesia’s Ministry of Communication and Informatics (KOMINFO) initiated the Government of Indonesia Multifunctional Satellite PPP Project to provide fast internet access to remote areas in Indonesia, which can be accessed by various government sectors, such as maritime, education, health, agriculture, communication and others. Satellite-based connectivity is the only feasible access technology to cost-effectively address these remote locations.

The Project is being executed by PT Pasifik Satelit Nusantara (PSN), the first private satellite-based telecommunication company in Indonesia, through its subsidiary PT Satelit Nusantara Tiga (SNT).  French aerospace manufacturer Thales Alenia Space is constructing the satellite which will have a capacity of 150 gigabytes/second in the Ka-Band frequency.

“This is the first telecommunication satellite PPP Project in Indonesia and will support the Government of Indonesia’s goal to provide connectivity to more than 149,000 Public Service Points in the country,” said White & Case partner Tom Bartlett, who co-led the Firm’s deal team. “These points will include schools, health centers and local villages, connecting approximately 45 million individuals.”

The financing was provided by a number of financial institutions including the Asian Infrastructure Investment Bank (AIIB), a multilateral financial institution focused on Asia and commercial banks, HSBC, Banco Santander and Korea Development Bank (KDB), and guaranteed by Banque publique d’investissement (Bpifrance), the French Export Credit Agency.

The White & Case and WCA team which advised on the transaction was led by partners Mukund Dhar and Tom Bartlett (both London) and included association partner Fajar Ramadhan (Jakarta), partners Jason Kerr, Swati Tripathi and Ingrid York (all London), partner of counsel Sylvia Chin (New York), counsel David Wright (London) and Fern Han (Houston), and associates Dayle Perles Fattal, Tom Wilkinson, Eduardo Barrachina and Matt Steele (all London), Deborah Victoria and Janet Lim (both Jakarta), Amr Jayousi (Houston), Surya Gopalan (New York) and Berdine Geh (Singapore).

Indonesia Issues Guidance for Online Licensing Service

The Indonesian Investment Coordinating Board (“BKPM”) on April 1, 2020, issued BKPM Regulation No. 1 of 2020 regarding Guidelines for the Implementation of Electronic Integrated Licensing Services (“BKPM Reg. 1/2020”).

The BKPM issued this regulation as part of its authority to provide guidance on business licensing services through the Online Single Submission System (the “OSS System”) under Article 94(1) of Government Regulation No. 24 of 2018 regarding Electronic Integrated Business Licensing Services (“GR 24/2018”) and Presidential Instruction No. 7 of 2019 regarding Acceleration of Ease of Doing Business.

With the issuance of BKPM Reg. 1/2020, the BKPM has set the norms, standards, procedures and criteria for the business licensing framework through the OSS System, as presently governed under BKPM Regulation No. 6 of 2018 regarding Guidelines and Procedures for Capital Investment Licensing and Facilities, and its amendment, BKPM Regulation No. 5 of 2019. BKPM Reg. 1/2020 does not revoke or amend any past BKPM regulations.

Scope of New Regulation

BKPM Reg. 1/2020 covers:

a. Services relating to:

i. access right to the OSS System;
ii. issuance of Business Registration Number (Nomor Induk Berusaha or “NIB”);
iii. business license;
iv. issuance of licenses related to business infrastructure;
v. representative offices; and
vi. other services relevant to business licensing.

b. Supervision of business licensing compliance.

Noteworthy Provisions

With 69 articles, BKPM Reg. 1/2020 provides technical guidance on the application for and the issuance of business licenses through the OSS System and a legal basis for new features implemented in OSS System version 1.1.

BKPM Reg. 1/2020 contains provisions applicable to all businesses, foreign and domestic, individuals or entities. However, we will limit our discussion here to provisions relevant to foreign investment. In that context, below are some of the more noteworthy provisions in BKPM Reg. 1/2020.

  • a. Minimum total investment value. In general, the BKPM requires a minimum total investment value of more than IDR 10 billion (excluding land and buildings) for each line of business per project location as determined by the five digits of its Indonesian Standard Business Classification (Klasifikasi Baku Lapangan Usaha Indonesia or “KBLI”) number.This means that if a foreign investment company, typically referred to as a PT PMA, intends to engage in the mining services business under KBLI No. 09900 and wholesale trading of office and industrial machinery, spare parts and paraphernalia, which falls under KBLI No. 46591, the total investment value of that company must be more than IDR 20 billion. Or if a PT PMA operates as a data center service provider under KBLI No. 63112, but does so in Jakarta, Surabaya, and Medan, the total investment value of that company must be more than IDR 30 billion because it has three separate project locations.

    This has long been an unwritten policy of the BKPM, albeit with inconsistent enforcement, and has now been made an express requirement under this new regulation.

    The BKPM provides the following exceptions for wholesale trading, food and beverages, and construction business activities:

1. For wholesale trading, the BKPM requires an additional minimum total investment value of more than IDR 10 billion if a PT PMA engages in wholesale trade activities under KBLI classification numbers whose first two digits are different. For example, if a PT PMA engages in wholesale trading of office and industrial machinery, spare parts and paraphernalia under KBLI No. 46591, and wholesale trading of new cars under KBLI No. 45101, the PT PMA will be required to have a minimum total investment value of more than IDR 20 billion because the first two digits of the KBLI numbers are different. In contrast, if a PT PMA engages in wholesale trading of bread products under KBLI No. 46332 and wholesale trading of confectionary items under KBLI No. 46331, the PT PMA will not be required to have a minimum total investment value of more than IDR 20 billion.

2. For food and beverage services that are open to foreign investment, the BKPM requires an additional minimum total investment value of more than IDR 10 billion only for project locations that are not in the same regency or city.

3. For construction services that are open to foreign investment, the BKPM requires an additional minimum total investment value of more than IDR 10 billion only if the business activity is not part of one activity. BKPM Reg. 1/2020 does not offer an explanation as to what constitutes one activity. However, in our discussions with a BKPM official, we were informed that this means an additional total investment value of more than IDR 10 billion would be required for each construction project/work. We note, however, that this view is far from official policy and is subject to change as the BKPM begins to put this regulation into actual practice.

Interestingly, the above total investment value requirement is being imposed on PT PMAs that obtained their license on or after the effective date of GR 24/2018, which was June 21, 2018, not after the effective date of BKPM Reg. 1/2020 itself. A possible explanation for this is that the BKPM intended to expressly impose this investment value requirement with the introduction of the OSS System by GR 24/2018, but the system was not yet capable of such implementation and now the BKPM is playing catch up with the rollout of the upgraded OSS System version 1.1.

  • b. NIB can be revoked. BKPM Regulation No. 7 of 2018 regarding Procedure and Guidance for the Supervision of Investment Implementation discusses the revocation of business licenses as one of the administrative actions the BKPM can take in its supervisory role, but it does not contemplate the revocation of NIBs.Under BKPM Reg. 1/2020, the BKPM can revoke a PT PMA’s NIB if it finds that the company has conducted business activities that are inconsistent with its NIB or has violated any provisions of prevailing laws and regulations, or if the PT PMA’s NIB is declared voided or invalid based on a binding court decision and/or the PT PMA requests the revocation of its NIB.
  • c. Main project and supporting project. Under OSS System version 1.1 and BKPM Reg. 1/2020, a PT PMA can now separate business activities into main project and supporting project. A business activity is considered to be a supporting project if it:1. falls under a different KBLI number than the main project;
    2. is intended only to support the main project;
    3. is not utilized to generate revenue; and
    4. is carried out in accordance with the applicable laws and regulations.

    A PT PMA is required to fulfill the commitments under both the main project and supporting project, although only the main project is used to determine the minimum total investment value.

  • d. Business licenses and commercial or operational licenses. BKPM Reg. 1/2020 addresses business licenses and commercial or operational licenses at length, particularly the technical details of fulfilling commitments related to the licenses. BKPM Reg. 1/2020 divides business licenses and commercial or operational licenses into four categories, depending on the commitments the PT PMA must fulfill to effectuate the relevant license. BKPM Reg. 1/2020 also changes the format of business licenses and commercial or operational licenses issued under BKPM Reg. 1/2020.BKPM Reg. 1/2020 also specifies measures to be taken by the BKPM in the event of incompliance by a PT PMA.

    e. BKPM to issue registration and licenses as well as NIB for representative offices. The BKPM now issues registration and licenses for all types of representative offices – foreign company representative office (KPPA), foreign trade company representative office (KP3A), foreign construction company representative office (BUJKA), foreign franchisor and foreign futures traders. A representative office is also required to obtain an NIB, in addition to the appropriate registration or licenses.

    Conclusion

    Through the issuance of BKPM Reg. 1/2020, it appears the BKPM is trying to minimize uncertainty in the licensing process. It remains to be seen, however, whether OSS System 1.1 itself and the enforcement in the field will raise more questions than BKPM Reg. 1/2020 can answer.

This publication is intended for informational purposes only and does not constitute legal advice. Any reliance on the material contained herein is at the user’s own risk. You should contact a lawyer in your jurisdiction if you require legal advice. All SSEK publications are copyrighted and may not be reproduced without the express written consent of SSEK.

Indonesia Targets Taxation of Tech Companies to Boost Economy

Indonesia is set to tax tech companies that may or may not have a legal presence in the country, as electronic transactions and the use of streaming services and online telecom apps have increased notably during the COVID-19 pandemic.

The legal basis for this measure is the recently enacted emergency bill Government Regulation in Lieu of Law No. 1 of 2020 regarding State Financial Policy and Financial System Stability for the Management of the Coronavirus or COVID-19 Pandemic and/or in Facing Threats to the National Economy and/or Financial System Stability (“GR 1/2020”).

Collection of VAT

Article 6 of GR 1/2020 states that the government will collect value-added tax (“VAT”) for intangible taxable goods and/or taxable services from outside Indonesia which are utilized in the country through electronic system trade activities, in accordance with Law No. 8 of 1983 regarding Value-Added Tax for Goods and Services and Sales Tax on Luxury Goods, as lastly amended by Law No. 42 of 2009. This VAT will be collected, deposited and reported by foreign traders, foreign service providers, foreign electronic trading system providers and/or domestic electronic trading system providers appointed by the Minister of Finance. These parties can appoint representatives domiciled in Indonesia to collect, deposit and report the VAT.

Procedures for the appointment of representatives and for the collection, deposit and reporting of the VAT are further regulated under Minister of Finance Regulation No. 48/PMK.03/2020 regarding Procedures for the Appointment of Collectors and for the Collection, Deposit and Reporting of VAT for the Use Inside the Customs Area of Intangible Taxable Goods and/or Taxable Services from Outside the Customs Area through Electronic System Trade Activities (“MOF Reg. 48/2020”).

Collection of Income Tax

The government will also collect income tax from foreign traders, foreign service providers and/or foreign electronic trading system providers that have a significant economic presence in Indonesia. The determination of “significant economic presence” is based on the consolidated gross turnover of the business group, sales in Indonesia, and number of active users on digital media in Indonesia. The threshold for these criteria are to be further regulated in a Minister of Finance regulation. A party that meets the threshold for a significant economic presence in Indonesia will be treated as a permanent establishment and subject to income tax.

If foreign traders, foreign service providers or foreign electronic trading system providers are determined to have a significant economic presence in Indonesia but cannot be treated as permanent establishments due to the application of agreements with other governments in the context of avoiding double taxation and the prevention of tax evasion, they will be subject to an electronic transaction tax.

Such income tax or electronic transaction tax is to be paid and reported by the foreign traders, foreign service providers and foreign electronic trading system providers. Similar to the VAT payment, parties are allowed to appoint representatives domiciled in Indonesia to fulfil their income tax or electronic transaction tax obligations.

The rate for the income tax or electronic transaction tax, its calculation, the procedures for tax payment and reporting, and the procedures for the appointment of representatives to fulfil tax obligations are to be further regulated by Minister of Finance regulation.

Sanctions

Foreign companies that do not comply with the above provisions are subject to administrative sanctions and could also have access to their apps blocked by the Minister of Communication and Informatics.

As the government implements large-scale social distancing restrictions and businesses apply work from home policies, the number of users of streaming services and online meeting apps has increased markedly.

The government has for years been aiming to collect taxes from foreign tech companies that enjoy significant revenue from Indonesia, but to no avail. It has been a struggle because of these companies’ lack of a physical presence in Indonesia, with prevailing tax regulations only covering companies domiciled in the country or those that can be considered permanent establishments.

This is a loophole in the era of the cross-border digital economy that GR 1/2020 tries to address. As noted by Indonesian Finance Minister Sri Mulyani Indrawati, under the new regulation a permanent establishment would no longer be defined solely on physical presence. Consequently, even if foreign tech companies do not open an office in Indonesia, they would still have tax obligations if they established a significant economic presence in the country.

For example, it has been reported that, pursuant to MOF Regulation 48/2020, the government will impose a 10% tax on subscription fees for streaming apps starting July 1, 2020.

Status of GR 1/2020 

It appears that these efforts to tax foreign tech companies will continue after the COVID-19 pandemic ends. Pursuant to Law No. 12 of 2011 regarding the Formulation of Laws and Regulations, as amended by Law No. 15 of 2019, an emergency bill must be submitted to the House of Representatives for approval. If it is approved by the House it will then become a law, and if it is rejected, the emergency bill will be revoked.

In this regard, the House has approved the adoption of GR 1/2020 as a law, resulting in the promulgation of Law No. 2 of 2020 regarding Stipulation of GR 1/2020 regarding State Financial Policy and Financial System Stability for the Management of the Coronavirus or COVID-19 Pandemic and/or in Facing Threats to the National Economy and/or Financial System Stability, This new law is effective as of May 18, 2020. (May 20, 2020)

This publication is intended for informational purposes only and does not constitute legal advice. Any reliance on the material contained herein is at the user’s own risk. You should contact a lawyer in your jurisdiction if you require legal advice. All SSEK publications are copyrighted and may not be reproduced without the express written consent of SSEK.