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feat(jurisdiction): add Indonesia OJK and Singapore MAS cards - #182

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mzf11125:jurisdiction-apac
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feat(jurisdiction): add Indonesia OJK and Singapore MAS cards#182
mzf11125 wants to merge 1 commit into
ethsystems:masterfrom
mzf11125:jurisdiction-apac

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@mzf11125 mzf11125 commented Aug 1, 2026

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Adds jurisdictions/id-OJK.md and jurisdictions/sg-MAS.md. The map currently covers Hong Kong and China in APAC and has no ASEAN coverage at all.

Indonesia

Supervision of crypto assets moved from the commodity futures regulator, Bappebti, to the financial services authority, OJK, effective 10 January 2025 under Government Regulation 49/2024, as mandated by the P2SK Law. The substantive change is reclassification: crypto is no longer a tradable commodity but a "digital financial asset" inside the financial services perimeter.

Current state, which has moved recently and is easy to get wrong:

  • POJK 27/2024, as amended by POJK 23/2025 (issued January 2026), which closed the transition phase
  • Law No. 4 of 2026, effective 17 June 2026, raising the taxonomy to primary law
  • A draft OJK regulation on digital financial asset offerings is still pending

The reason this card belongs in a privacy map is a listing criterion. POJK 27/2024 requires traded assets to be traceable and bars assets whose features conceal ownership or transaction information. That is a direct, named restriction on privacy technology in a G20 market, and no other card in the folder documents a rule of that shape. Indonesia is permissive toward tokenised finance and explicitly restrictive toward on-chain confidentiality.

Crypto also remains prohibited as a payment instrument, since the Currency Law makes the rupiah sole legal tender.

Singapore

Permissive and heavily licensed. Digital payment token services sit under the Payment Services Act 2019, and since 30 June 2025 a separate DTSP regime under the Financial Services and Markets Act 2022 captures Singapore-incorporated firms serving customers wholly abroad. That regime commenced with no transition window.

One claim deliberately pulled back: the single-currency stablecoin framework was finalised as policy in August 2023, but the implementing legislation has not been introduced in Parliament, so the card records it as not yet in force rather than as law.

Scope

Both follow jurisdictions/_template.md. Cross-linked to each other and to the existing Hong Kong and China cards, which gives the map its first connected APAC cluster.

Checks

  • CI_MODE=strict npm run validate passes with zero warnings against either file
  • check-terms clean
  • Vale clean on both

CHANGELOG entry added under [Unreleased].

Gives the map its first ASEAN coverage, alongside the existing Hong
Kong and China cards.

Indonesia: supervision moved from Bappebti to OJK on 10 January 2025,
crypto reclassified as a digital financial asset under POJK 27/2024 as
amended by POJK 23/2025, with Law No. 4 of 2026 raising the taxonomy to
primary law. The card leads on the listing criterion that requires
traceability and bars assets whose features conceal ownership or
transaction information, which is a direct restriction on on-chain
confidentiality in a G20 market.

Singapore: DTSP regime under the FSM Act live since 30 June 2025 with
no transition window. The single-currency stablecoin framework is
recorded as finalised policy that is not yet in force, since the
implementing legislation has not been introduced in Parliament.
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