The first requirement is correct activity classification. Indonesian regulators assess what the company actually does: order matching, brokerage, client onboarding, custody, settlement support, wallet control, token listing involvement or platform operation. A weak perimeter memo is one of the fastest ways to delay a project.
The second requirement is local substance. In practice, applicants should expect scrutiny of the Indonesian legal entity, ownership chain, directors, governance, office arrangements, internal controls and operational capability. High-risk structures with nominee-heavy ownership or unclear source of funds typically create avoidable friction.
The third requirement is a functioning compliance model before filing. Regulators usually expect more than a template AML policy. They look at onboarding flows, sanctions screening, transaction monitoring, suspicious activity escalation, wallet control logic, outsourcing oversight and recordkeeping discipline.