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Fair Finance Watch is a Non-Governmental Organization Focused on the Fairness of the Financial Services Industries - Banking, Insurance and Securities - to Local Communities, Urban and Rural, North and (Global) South, including under Human Rights Laws

FFW researches, documents and advocates around financial firms' activities, and how they affect local communities. The profiles below are in-process -- For or with more information, contact us.


Indonesia Pakistan   Philippines   Singapore  Vietnam (lack of transparency)


Indonesian banking law with respect to “Merger, Consolidation, and Acquisition” --

Indonesia requires prior approval, under a standard that includes not only antitrust but also that “the interest of the Customers” not be harmed.  See, Law Concerning the Banking System, Article 28 -- (1) Merger, Consolidation, and Acquisition shall be subject to prior approval from the Chairmen of Bank Indonesia. (2) Provisions concerning merger, consolidation, and acquisition shall be stipulated in a Government Regulation.

As Amended By : The Act Of The Republic of Indonesia Number 10 of 1998. Paragraph (1) In conducting Merger, Consolidation, and Acquisition, the parties shall prevent a concentration of economic power within one group in the form of a monopoly detrimental to the public interest. A Merger, Consolidation, and Acquisition shall not harm the interest of the Customers.

Regulatory contact:

Bank Indonesia
Jl. MH. Thamrin 2 Jakarta 10110 Indonesia
Tel: (62-21) 381-7187
Fax: (62-21) 350-1867
E-mail :

Agency self-description: “In conducting banking regulatory and supervisory task, Bank Indonesia issues regulation, grants and revokes bank's license or certain banking activities permit, conducts banking supervisory and imposes sanction to bank in accordance to the law of the land. In conducting these tasks, Bank Indonesia, with utmost prudence, is authorized to enact banking regulations.

In the context of the Bank's authority in bank licensing, asides from granting and revoking business license of the banking institutions, Bank Indonesia may grant permit in opening, closing and moving of bank's branch office, grant approval of bank's ownership and management, also grant permit to bank concerning particular business activities.

The Bank's supervisory authority takes the form of direct and indirect monitoring. Direct supervision is conducted through on-site examination regularly or randomly as needed. Indirect supervision is conducted through research, analysis and evaluation of submitted banks report.”



Regulator and central bank:

State Bank of Pakistan
I.I. Chundrigar Road, Karachi, Pakistan.
Phone: (+92-21)-24450298, Fax: (+92-21) 9212440

Regarding service to "unbanked area," the State Bank of Pakistan in October 2004 "decided that, henceforth, every bank should open at least 20% of branches planned to be opened, under its annual branch expansion plan, in unbanked areas. Banks are advised to keep this in view while submitting their annual branch expansion plan for year 2005 and onwards. The above instructions will not be applicable to Microfinance Banks, Islamic Banks, Islamic Banking subsidiaries of existing commercial banks and stand alone Islamic Banking branches of commercial banks."

The next month, a second exemption was added: the "condition of opening 20% branches in unbanked areas shall not be applicable in case of bank having 100 or less branches."

  Even with these exemptions, the IMF / World Bank in a subsequent 18-page Technical Note opined that "the newly privatised banks still face several challenges, including... the maintenance of loss-making branches in the 'unbanked' areas."  See, Business Recorder of May 12, 2005.


Bangko Sentral ng Pilipinas
A. Mabini St. cor. P. Ocampo St.,
Malate Manila, Philippines 1004
Tel. No. : (632) 524-7011
Fax No. : (632) 523-1252

Manual of Regulations for Banks (in PDF)


Singapore’s banking law with respect to acquiring 20% or more of another institution:

            Singapore requires prior approval for a bank to acquire 20% or more of another institution, and provides that the Monetary Authority of Singapore does not have to give any reasons for approving (or denying) such an application.  When MAS was commented to an a cross-border acquisition there, approval was granted without any reason being given (see below).  For the law, see, Banking Act, Section 32 (1) --

No bank shall enter into an agreement to acquire the share capital of any company by virtue of which the bank would, if the agreement is carried out, acquire or hold, directly or indirectly, an interest of 20% or more of the share capital of that company, without first notifying the Authority of its intention to enter into the agreement and obtaining the approval of the Authority to its entering into the agreement.

Section 32 (2)  The Authority may approve the entering into the agreement with or without conditions or may disapprove it without giving any reasons.

Regulatory contact

Monetary Authority of Singapore
Financial Supervision Group
10 Senton Way
MAS Building
PO Box 52
Singapore 079117
Tel: 65 2 255 577
Fax: 65 2 299 229
E-mail: webmaster [at]

"MAS oversees the banking, securities, futures and insurance industries."

Banking law:  see,

Some experience: In a message dated 2/17/03 4:03:51 AM Eastern Standard Time, writes:

Dear Mr Lee,

Thank you for your email and fax.

We noted the information provided in your email and have given them due
consideration in our deliberations on the acquisition of Keppel Insurance
by HSBC Holdings Plc. We thank you for your interest in the subject.

Yours truly,

Hauw Soo Hoon
Executive Director
Insurance Supervision Department
Monetary Authority of Singapore

and see
(Challenges to HSBC's "Takeover Bids For Us Finance Firm And Keppel Insurance")



FFW: In Vietnam, transparency is lacking. In the last week of 2005, after the fact, HSBC announced that it has finagled regulatory approval to buy 10% of Vietnam Technological and Commercial Joint Stock Bank (known as Techcombank) for $17.3 million. Hanoi-based Techcombank is Vietnam's third largest joint stock bank, with total assets of $482 million in 45 branches in 10 provinces and cities in Vietnam. HSBC's Alain Cany bragged that regulatory approval has already been received - before HSBC made any public announcement or disclosure of the proposal…

and see


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 United States          FFW Campaigns    In Other Media      Non-USA/Global

         FFW researches, documents and advocates around financial firms' activities, and how they affect local communities. FFW files its findings with tribunals, regulatory agencies, and elsewhere, including on this Web site . Click here to view analyses of several multinational financial institutions' effects on consumers and the environment, worldwide: for two examples, Citigroup and HSBC. Click here for some initial brainstorming on the application of human rights and international law to the global financial services companies, and for citations (where possible, links) to resource material.  Click here for some September 2004 campaigns -- PNC/Riggs (Finance Watch Reports of August 16, 2004, onwards), J.P. Morgan Chase, etc..  Click here for an ongoing report on the campaign to reform anti-money laundering, tax haven, and bank secrecy laws.   Click here for the Human Rights Enforcement project, including its new (9/04) criminal justice and local human rights project. For or with more information, contact us.

For More information, see:
Human Rights & Finance: Predatory Lending in a Deregulated Network Economy

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Phone: (718) 716-3540. Fax: (718) 716-3161. E-mail: Staff [at]