* Terrorist Safe Haven - Suluwesi/Sulu Sea region
|
FATF Statement re AML Strategic Deficiencies:
Date: 16 February 2012
Indonesia has taken significant steps towards improving its
AML/CFT regime, including by enacting AML legislation in 2010
and developing draft comprehensive CFT legislation. Despite
Indonesia’s high-level political commitment to work with the FATF
and APG to address its strategic AML/CFT deficiencies, Indonesia
has not made sufficient progress in implementing its action plan,
and certain strategic AML/CFT deficiencies remain. Indonesia
should work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist
financing (Special Recommendation II); (2) establishing and
implementing adequate procedures to identify and freeze terrorist
assets (Special Recommendation III); and (3) amending and
implementing laws or other instruments to fully implement the
1999 International Convention for the Suppression of Financing of
Terrorism (Special Recommendation I). The FATF encourages
Indonesia to address its remaining deficiencies and continue the
process of implementing its action plan.
____________________________________________________
Sanctions:
None applicable
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2012:
While Indonesia is neither a regional financial center nor an
offshore financial haven, the country remains vulnerable to money
laundering and terrorist financing due to its weak anti-money
laundering/counter-terrorist financing (AML/CFT) regime, cash-
based economy, weak rule-of-law and ineffective law enforcement
institutions, and the presence of major indigenous terrorist
groups, such as Jemaah Islamiyah (JI), a loose network of JI spin-
off groups, and Jemaah Anshorut Tauhid, which obtain financial
support from both domestic and foreign sources. Most money
laundering in the country is connected to non-drug criminal
activity such as corruption, illegal logging, theft, bank fraud, credit
card fraud, maritime piracy, sale of counterfeit goods, gambling
and prostitution.
Indonesia has a long history of smuggling of illicit goods and bulk
cash, facilitated by thousands of miles of unpatrolled coastline,
sporadic law enforcement, and poor customs infrastructure.
Proceeds from illicit activities are easily moved offshore and
repatriated as needed for commercial and personal use. While
Indonesia has made some progress in combating official
corruption via a strong yet embattled Corruption Eradication
Commission, endemic corruption remains a significant concern
and poses a challenge for AML/CFT regime implementation.
In an October 2011 report, the Financial Action Task Force
(FATF) noted that Indonesia continues to have certain strategic
AML/CFT deficiencies, including a lack of progress on the
implementation of its action plan. Of particular concern is
Indonesia’s failure to pass terrorist financing and asset forfeiture
legislation.
For additional information focusing on terrorist financing, please
refer to the Department of State’s Country Reports on Terrorism,
which can be found here: http://www.state.gov/j/ct/rls/crt/
Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of US currency; currency derived from illegal sales in the
U.S.; or that otherwise significantly affect the U.S.: NO
Criminalization of Money Laundering:
“All serious crimes” approach or “list” approach to predicate
crimes: Combination approach
Legal persons covered: criminally: YES civilly: YES
Know-your-customer (KYC) rules:
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES
KYC covered entities: Banks, finance companies, insurance
companies and insurance brokerage companies, pension fund
financial institutions, securities companies, investment managers,
providers of money remittance, and foreign currency traders
Suspicious Transaction Reporting (STR) Requirements:
Number of STRs received and time frame: 16,054 from January
through October 2011
Number of CTRs received and time frame: 1,412,769 from
January through October 2011
STR covered entities: Banks, financing companies, insurance
companies and insurance brokerage companies, pension fund
financial institutions, securities companies, investment managers,
custodians, trustees, postal services as providers of fund transfer
services, foreign currency changers (money traders), providers of
payment card services, providers of e-money or e-wallet services,
cooperatives doing business as savings and loan institutions,
pawnshops, commodity futures traders, money remitters, property
companies and agents, car dealers, dealers of precious stones
and jewelry/precious metals, art and antique dealers, and auction
houses
Money Laundering Criminal Prosecutions/Convictions:
Prosecutions: Not available
Convictions: Four from January through October 2011
Records exchange mechanism:
With U.S.: MLAT: NO Other mechanism: YES
With other governments/jurisdictions: YES
Indonesia is a member of the Asia/Pacific Group on Money
Laundering (APG), a Financial Action Task Force (FATF)-style
regional body. Its most recent mutual evaluation can be found
here: http://www.apgml.org/documents/docs/17/Indonesia%
20MER2_FINAL.pdf
Enforcement and implementation issues and comments:
In October 2010, the Government of Indonesia (GOI) enacted a
new AML law that partially complies with international standards.
Among other improvements, the law expands the list of agencies
permitted to conduct money laundering investigations, gives the
independent financial intelligence unit (FIU), PPATK, more
authority to examine suspicious financial transactions, and
increases some criminal penalties for money laundering offenses.
Personnel in both the executive and judicial branches should
receive more training to effectively implement and enforce the
expanded provisions of the AML law.
Indonesia’s PPATK is a dynamic and effective FIU that works
closely with the Central Bank to oversee and implement Indonesia’
s anti-money laundering regime. PPATK is well-funded and has
an experienced and effective leadership team in place. The
October 2010 AML legislation, however, has taxed the institution’s
capacity and PPATK will need a significant increase in staff to
meet its responsibilities under the law. In an effort to place some
of the legal burden on industry and bank partners, PPATK will
open three anti-money laundering centers in different regions of
Indonesia to serve as resource centers for organizations that
must comply with the new regulations.
Despite a stated high-level commitment to the action plan
developed to address some of the persistent gaps in its AML/CFT
legislation, the GOI has not met its projected timeframes.
Essential draft CFT legislation will not be submitted to parliament
until at least early 2012, more than a year later than originally
expected. Passage may be further delayed by disagreements
over various provisions, including those addressing forfeiture of
unexplained wealth and new reporting requirements for religious
institutions.
Indonesia continues to lack an effective mechanism to implement
UNSCRs 1267 and 1373. The October 2010 AML legislation only
provides for the temporary suspension of terrorist assets linked to
the UN list of designated terrorists and terrorist organizations and
does not allow for an immediate and ongoing freeze. Corruption,
particularly within the police ranks, impedes effective
investigations and prosecutions. Prosecutors and judges should
be given additional training on tracing and documenting financial
flows and presenting this evidence convincingly in court.
____________________________________________________
US State Dept Narcotics Report 2012 (introduction):
Indonesia faces continuing challenges in combating drug
production, trafficking, and internal drug use. Provisions of
Indonesia’s new National Narcotics Law approved in October
2009 have provided the Indonesian National Narcotics Board
(BNN) with increased resources and new mandates in the areas
of enforcement, demand reduction, and treatment of drug users.
However, the Government of Indonesia (GOI) still faces major
future challenges, especially in combating a growing use of
methamphetamines by Indonesian youth.
As of mid-2011, Indonesia had a population of approximately 4.1
million drug abusers (ca. 2 percent of Indonesia’s population), an
increase of roughly 500,000 since 2009. During a September
2011 International Drug Enforcement Conference in Bali, the BNN
Director stated that crime associated with drugs increased by 67
percent during the first six months of 2011 compared to the
previous six months. The BNN Director added that, while drug
usage has typically been associated with the country’s larger
cities, it is now spreading to smaller villages in many parts of the
archipelago. He also commented that 80 percent of the country’s
drug addicts are between the ages of 15 and 39 years, reflecting
the growing use of methamphetamines by young Indonesians.
The growing demand for methamphetamines, ecstasy, heroin,
and ketamine is reflected in higher seizure rates and higher street
prices in Indonesia than in most other Southeast Asian countries.
Most methamphetamine, heroin, and associated precursors still
come from Iran, Afghanistan, Pakistan, China, Thailand, Taiwan,
and India. However, small domestic laboratories, often located in
residences, produce a significant and growing amount of
methamphetamine and ecstasy. Typically the labs are run by
Indonesian drug syndicates or have an ethnic Chinese connection.
Most foreign drug smugglers caught with methamphetamine are
associated with Iranian, West African/Nigerian, or Malaysian drug
syndicates. Because Indonesian drug prices are high relative to
other Southeast Asian countries, the Indonesian market offers a
high profit margin as an added incentive to increase smuggling
operations into the country. For example, methamphetamine can
command a street value more than 10 times its cost in Iran.
Drugs smuggled into Indonesia typically transit Malaysia,
Singapore, Thailand, or arrive directly on flights originating from
Iran, Turkey, and other travel hubs in South Asia and the Middle
East. Methamphetamine and associated precursors originating
from China, Hong Kong, or Taiwan are brought in via ship. The
April 2011 seizure of 17.9 kilograms of Iranian-sourced
methamphetamine concealed in a shipping container in Jakarta’s
port of Tanjung Priok and the increased frequency of air cargo
shipments containing narcotics represent two of the more
significant drug trends during the past year. There has also been
a tangible increase in illegal ketamine importation over the past
year. Most of the ketamine originates in India, but small amounts
from China have also been detected. Cannabis seizures have
been gradually declining.
For Full report, click here
____________________________________________________
US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 2)
Indonesia is a major source country, and to a much lesser extent
a destination and transit country for women, children, and men
who are subjected to sex trafficking and forced labor. Each of
Indonesia’s 33 provinces is a source and destination of trafficking,
with the most significant source areas being Java, West
Kalimantan, Lampung, North Sumatra, and South Sumatra. A
significant number of Indonesian migrant workers face conditions
of forced labor and debt bondage in more developed Asian
countries and the Middle East – particularly Malaysia, Saudi
Arabia, Singapore, Kuwait, Syria, and Iraq. The number of
Indonesians seeking work abroad remains very high, with an
estimated 6.5 million to 9 million Indonesian migrant workers
worldwide, including 2.6 million in Malaysia and 1.8 million in the
Middle East. An estimated 69 percent of all overseas Indonesian
workers are female. IOM and a leading Indonesian anti-trafficking
NGO estimates that 43 to 50 percent – or some 3 to 4.5 million – of
Indonesia’s expatriate workforce are victims of conditions
indicative of trafficking. Of 3,840 trafficking victims IOM and the
Indonesian government identified upon their return from work
overseas, 90 percent were female and 56 percent had been
exploited in domestic work. According to IOM, a total of 82 percent
of victims identified in 2010 had been trafficked abroad; 18
percent were trafficked within Indonesia. During voluntary
interviews, these Indonesian trafficking victims reporting
experiencing the following forms of abuse, all conducive to
trafficking: withheld salary (85 percent); excessive working hours
(80 percent); total restriction of movement (77 percent); verbal or
psychological abuse (75 percent); and confiscation of travel
documents (66 percent). The number of Indonesian women who
are raped while working as domestic workers appears to be on
the rise. Based on a 2010 survey, a respected Indonesian NGO
noted that during the year 471 Indonesian migrants returned from
the Middle East pregnant as the result of rape, and an additional
161 returned with children who had been born in the Middle East.
Half of the victims of trafficking within the country were children,
while 70 percent of victims trafficked abroad were adults.
According to IOM, labor recruiters, both legal and illegal, are
responsible for more than 50 percent of the Indonesian female
workers who experience trafficking conditions in destination
countries. Some recruiters work independently, others for
recruitment labor companies called PJTKIs (which include both
legal and illegal companies). Some PJTKIs operate similar to
trafficking rings, leading both male and female workers into debt
bondage and other trafficking situations. These recruitment
brokers often operate outside the law with impunity and some
PJTKIs use ties to government officials or police to escape
punishment. There are reports of workers recruited for overseas
work by PJTKIs being confined involuntarily for months in
compounds – ostensibly for training and processing – prior to their
deployment, accumulating debts that make them vulnerable to
debt bondage. Licensed and unlicensed companies used debt
bondage, withholding of documents, threats of violence, and
confinement in locked premises for extended periods to keep
Indonesian migrants in situations of forced labor.
Indonesian women migrate to Malaysia, Singapore, and the
Middle East and are subsequently subjected to forced
prostitution; they are also subjected to forced prostitution and
forced labor in Indonesia. According to the Director General for
the Development of Tourist Destinations, an estimated 40,000 to
70,000 Indonesian children have been exploited in prostitution
within the country. Children are trafficked internally and abroad
primarily for domestic servitude, forced prostitution, and cottage
industries. Many of these trafficked girls work 14-16 hours a day
at very low wages, often under perpetual debt due to pay
advances given to their families by Indonesian brokers. Debt
bondage is particularly pronounced among sex trafficking victims,
with an initial debt of some $600 to $1,200 imposed on victims;
given an accumulation of additional fees and debts, women and
girls are often unable to escape this indebted servitude, even
after years in prostitution. Sixty percent of children under 5 years
old do not have official birth certificates, putting them at higher
risk for trafficking. Traffickers employ a variety of means to attract
and control victims, including promises of well-paying jobs, debt
bondage, community and family pressures, threats of violence,
rape, false marriages, and confiscation of passports.
A trend of recruitment of Indonesian migrant workers in Malaysia
for Umrah, a religious pilgrimage to Mecca continued during the
year; once in the Saudi Kingdom, Indonesian migrants are
trafficked to other points in the Middle East. A greater number of
Indonesian girls were recruited into sex trafficking through Internet
social networking media during the year. Traffickers also resorted
to outright kidnapping of girls and young women for sex trafficking
within the country and abroad. More than 25 sex trafficking victims
from Uzbekistan were identified in 2010, and there were reports of
victims from China, Thailand, other Central Asian countries, and
Eastern Europe exploited in Indonesia.
Internal trafficking is also a significant problem in Indonesia, with
women and girls exploited in domestic servitude, commercial
sexual exploitation, and in forced labor in rural agriculture, mining,
and fishing. Many victims were originally recruited with offers of
jobs in restaurants, factories, or as domestic workers before they
were coerced into prostitution. Child sex tourism is prevalent in
most urban areas and tourist destinations, such as Bali and Riau
Island. Some traffickers continued to forge partnerships with
school officials to recruit young men and women in vocational
programs for forced labor on fishing boats through fraudulent
“internship” opportunities. In April 2011, the government
established the National Coalition for the Elimination of
Commercial Sexual Exploitation of Children at the University of
Indonesia as a first step to addressing the problem.
The Government of Indonesia does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. During the year, the
government undertook efforts to improve coordination and
reporting of its anti-trafficking efforts. However, the government
did not enact necessary migrant worker legislation or apply
sufficient criminal sanctions to labor recruiters who subject
Indonesian migrants to labor trafficking. Moreover, the
government did not demonstrate vigorous efforts to investigate,
prosecute, and criminally punish law enforcement officials
complicit in human trafficking, and this remained a severe
impediment to the government’s and NGOs’ anti-trafficking efforts.
During the year, the Indonesian government undertook a number
of reforms that significantly improved the coordination and
effectiveness of the 19 ministries and agencies involved in
addressing human trafficking. The government clarified the role of
the National Agency for Placement and Protection of Indonesian
Overseas Workers (BNP2TKI) in implementing the 2004 migrant
labor law (Law No. 39), which created the agency. It also enacted
a new immigration law that provides additional tools with which to
fight the complicity of law enforcement officials in human
trafficking and smuggling, and advanced draft legislation to
protect migrant workers, including trafficking victims, more
effectively. Recognizing the high vulnerability of female migrant
workers in some receiving countries, the Indonesian government
imposed a ban on its certification of additional Indonesian female
migrants going to Saudi Arabia and Jordan; it continued an earlier-
imposed ban on female migrants going to Malaysia.
For full report click here
____________________________________________________
US State Dept Terrorism Report 2010
Overview: In 2010, the Indonesian government continued to build
counterterrorism capacities, successfully prosecuted a number of
terrorists, and strengthened legislative efforts to counter terrorist
financing. A new National Counterterrorism Agency (BNPT) was
formally established on July 16 and President Yudhoyono swore
in retired Police Inspector General Ansyaad Mbai as its head on
September 7.
In February 2010, Indonesian police discovered a large
paramilitary terrorist training camp in Aceh. Officials identified at
least eight terrorist factions involved in the terrorist training camp.
The factions included militants who trained in Mindanao in the
southern Philippines, graduates of terrorist training camps in
Afghanistan and Pakistan, students, government workers, and
released terrorist convicts who had undergone de-radicalization
programs while in the Indonesian corrections system. Police
believed the Aceh-based terrorist group intended to target
Indonesian government officials, including President Susilo
Bambang Yudhoyono.
The success of police actions following the breakup of the Aceh
training camp, however, continued to demonstrate increased
police capacities, including successful operations carried out with
a minimum loss of life to both terrorists and civilians, though some
terrorists were killed during police raids. Police captured over 120
terrorists associated with the Aceh training camp, including
Abdullah Sunata, a leader of the radical group Kompak, known for
its involvement in ethnic conflicts in Poso and Ambon, and Abu
Tholut, a bomb maker believed to have funded the Aceh terrorist
training camp. In addition, the death of a third well-known terrorist,
Dulmatin, an electronics expert and bomb maker who received al-
Qa’ida training in Afghanistan and was wanted in connection to
the 2002 Bali bombing, brought to an end an intensive
international manhunt across Southeast Asia.
The number of corrections recidivists involved in the Aceh training
camp concerned the Indonesians. At least 18 recidivists were
either killed or captured in police actions connected to the camp.
The Government of Indonesia recognized that the high rate of
recidivism was one of a number of concerns related to the
Indonesian prison system that needed to be addressed. Prison
sector issues also included rehabilitative capacity, security
procedures, organizational structure, and training. Evidence that
terrorists within and outside of the corrections system (including
Dulmatin) were in contact with each other and were able to further
develop terrorist networks while incarcerated further highlighted
the need for broad prison reform.
2010 Terrorist Incidents: On the heels of successful police
actions, militants conducted retribution strikes against police
stations. On March 12, terrorists associated with the Aceh training
camp attacked a police outstation in Aceh. On September 22,
after a series of police actions in North Sumatera, 12 heavily-
armed men on six motorcycles killed three police officers in a
heavy-arms attack on a sub-district police station.
Indonesian law enforcement authorities believe terrorists
conducted a series of bank robberies to finance terrorist activities.
The most brazen bank robbery took place midday August 18
when 16 heavily armed robbers robbed a bank in the Medan
central commercial district. The robbers killed a police officer and
wounded two bank security guards.
Legislation and Law Enforcement: While Indonesia’s Terrorism
and Transnational Crime Task Force has a successful track
record in prosecuting terrorism cases, the 2010 arrests linked to
terrorist camps in Aceh revealed a limitation in Indonesia’s ability
to counter terrorism; nothing in Indonesian law directly
criminalizes participation in terrorist training camps. The Ministry
of Law and Human Rights formed an inter-agency working group
to draft amendments to Indonesia’s 2003 Terrorism law to
address deficiencies in the current law. In addition, draft
legislation to address the use of intelligence information in
terrorism cases was also in progress.
One major development in terms of pending legislation was the
formal establishment of the BNPT. On July 16, Presidential
Decree Number 46/2010 formally established the BNPT as a free-
standing agency. The new agency replaced the Anti-Terrorism
Coordinating Desk, which was housed in the Coordinating Ministry
for Political, Legal, and Security Affairs. On September 7,
President Yudhoyono swore in retired Police Inspector General
Ansyaad Mbai as the head of the BNPT. Mbai reported directly to
the President and attended relevant cabinet sessions. However,
the Coordinating Ministry for Political, Legal, and Security Affairs
retained oversight over the BNPT, similar to its oversight over
other ministries or agencies, including the Foreign Ministry,
National Intelligence Agency (BIN), and the Indonesian National
Police. The BNPT’s organizational structure contained a
secretariat responsible for administration and program
coordination, three deputies responsible for prevention,
protection, and de-radicalization efforts; operations and
capabilities; and international cooperation.
In addition, the Indonesian National Police’s (INP)
counterterrorism unit, Special Detachment 88, was separated
from the INP’s Criminal Investigation Unit and placed under the
BNPT deputy responsible for operations and capabilities, but
remained under the direct command of the national police chief. In
a move to consolidate their efforts, provincial Detachment 88 units
were abolished and replaced with 10 regional units.
Prosecutions: In 2010, the Attorney General’s Office Task Force
on Terrorism and Transnational Crime (SATGAS) secured
convictions of 11 terrorists connected with the 2009 bombings of
the J.W. Marriott and Ritz-Carlton hotels in Jakarta. A twelfth
defendant, Saudi national Al Khalil Ali, was charged with financing
the July 17, 2009 twin Jakarta hotel bombings under Indonesia’s
fledgling terrorist finance law. Ali was acquitted of the terrorism
charge on June 28, 2010, but found guilty of immigration
violations and sentenced to 18 months imprisonment.
SATGAS prosecutors have developed extensive experience
prosecuting terrorism cases, which are brought under a
specialized terrorism law with different procedures than ordinary
criminal cases. SATGAS prosecutors have developed long-term,
close professional relationships with the specialized police unit,
Detachment 88, which investigates Indonesia’s terrorism cases.
This has led to a new criminal model in Indonesia – police and
prosecutors working together on cases from the onset instead of
prosecutorial engagement beginning after a police investigation
has concluded. At the end of 2010, SATGAS was currently
prosecuting more than 70 defendants associated with the Aceh
training camp.
Border Security: Since 2006, a photo and 10 fingerprints have
been taken for all passport applicants. This information was sent
back to a central site for biometric checking which ostensibly must
be completed before a passport can be issued. However,
duplicative passports with false identities were easily obtainable.
This systemic weakness was highlighted when police discovered
that Muhammad Jibriel Abdur Rahman, aka Muhammad Ricky
Ardhan, who was sentenced in 2010 to five years in jail for his role
in the July 17, 2009 Jakarta bombings, was found to possess one.
In addition, when terrorist Dulmatin was killed in March 2010 press
reports state he had an Indonesian passport issued by the East
Jakarta Immigration Office in the name of Yahya Ibrahim. The
Government of Indonesia has noted the weaknesses in official
documentation controls and has been working to address the
issue.
Countering Terrorist Finance: Indonesia demonstrated concrete
progress in improving its Anti-Money Laundering/Countering
Financing of Terrorism (AML/CTF) regime. In February, the
government committed to work with the Financial Action Task
Force and the Asia/Pacific Group (APG) to address remaining
AML/CTF deficiencies.
On October 22, President Yudhoyono signed Law No. 8 of 2010
on the Prevention and Eradication of the Crime of Money
Laundering, which will help Indonesia counter terrorist finance and
transnational crime. The legislation permits rapid freezing and
seizure of assets and bank accounts, which will make it easier for
Indonesia to comply with UNSCRs 1267 and 1373 and bolster the
ability of police and prosecutors to pursue individuals who provide
critical financial support to terrorists. This law expanded the
number of agencies permitted to conduct money laundering
investigations; increased the ability of the independent Financial
Intelligence Unit (PPATK) to examine suspicious financial
transactions; expanded institutions authorized to obtain results of
PPATK analysis or examination of transactions; created a
streamlined mechanism to seize and freeze criminal assets;
expanded the entities which must file reports with PPATK; and
increased some criminal penalties for money laundering offenses.
The law designated non-financial businesses, in addition to
Indonesian banks and providers of financial services, which were
required to report suspicious transactions to PPATK. Throughout
the remainder of 2010, the PPATK led a government team
preparing regulations and guidelines to implement the new law.
The government was in the process of developing a
comprehensive bill on countering terrorist financing at year’s end.
In addition, the Central Bank issued new regulations, effective
December 1, which apply to all rural banks and require more
extensive provisions for due diligence for high-risk customers and
politically exposed persons, and checks against the Central Bank’
s Terrorist List, based on data published by the UN.
Regional and International Cooperation: Indonesia signed the
Beijing Convention on the Suppression of Unlawful Acts Relating
to International Civil Aviation and the Beijing Protocol to the
Convention for the Suppression of Unlawful Seizure of Aircraft at
the conclusion of an International Civil Aviation Organization
diplomatic conference in September.
Countering Radicalization and Violent Extremism: While Indonesia’
s new BNPT has stated its intent to incorporate counter-
radicalization into its overall counterterrorism strategy, civil society
organizations continued to take the lead in developing and
implementing counter-radicalization programs at the local level.
For example, the Association for Victims of Terrorism Bombings in
Indonesia, which includes family members of victims of terrorism in
Indonesia, worked to counter violent extremism through public
outreach events held at schools and for communities in Indonesia.
The corrections system lacked formal rehabilitation and
reintegration programs for all prisoners, including terrorists. As
with counter-radicalization, the BNPT stated it intended to play a
more significant role in de-radicalization efforts moving forward.
____________________________________________________
Links:
Worldwide AML Legislation (International Bar Association)
Indonesian Financial Transaction Reports and Analysis Centre
(INTRAC)
Date: 16 February 2012
Indonesia has taken significant steps towards improving its
AML/CFT regime, including by enacting AML legislation in 2010
and developing draft comprehensive CFT legislation. Despite
Indonesia’s high-level political commitment to work with the FATF
and APG to address its strategic AML/CFT deficiencies, Indonesia
has not made sufficient progress in implementing its action plan,
and certain strategic AML/CFT deficiencies remain. Indonesia
should work on implementing its action plan to address these
deficiencies, including by: (1) adequately criminalising terrorist
financing (Special Recommendation II); (2) establishing and
implementing adequate procedures to identify and freeze terrorist
assets (Special Recommendation III); and (3) amending and
implementing laws or other instruments to fully implement the
1999 International Convention for the Suppression of Financing of
Terrorism (Special Recommendation I). The FATF encourages
Indonesia to address its remaining deficiencies and continue the
process of implementing its action plan.
____________________________________________________
Sanctions:
None applicable
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2012:
While Indonesia is neither a regional financial center nor an
offshore financial haven, the country remains vulnerable to money
laundering and terrorist financing due to its weak anti-money
laundering/counter-terrorist financing (AML/CFT) regime, cash-
based economy, weak rule-of-law and ineffective law enforcement
institutions, and the presence of major indigenous terrorist
groups, such as Jemaah Islamiyah (JI), a loose network of JI spin-
off groups, and Jemaah Anshorut Tauhid, which obtain financial
support from both domestic and foreign sources. Most money
laundering in the country is connected to non-drug criminal
activity such as corruption, illegal logging, theft, bank fraud, credit
card fraud, maritime piracy, sale of counterfeit goods, gambling
and prostitution.
Indonesia has a long history of smuggling of illicit goods and bulk
cash, facilitated by thousands of miles of unpatrolled coastline,
sporadic law enforcement, and poor customs infrastructure.
Proceeds from illicit activities are easily moved offshore and
repatriated as needed for commercial and personal use. While
Indonesia has made some progress in combating official
corruption via a strong yet embattled Corruption Eradication
Commission, endemic corruption remains a significant concern
and poses a challenge for AML/CFT regime implementation.
In an October 2011 report, the Financial Action Task Force
(FATF) noted that Indonesia continues to have certain strategic
AML/CFT deficiencies, including a lack of progress on the
implementation of its action plan. Of particular concern is
Indonesia’s failure to pass terrorist financing and asset forfeiture
legislation.
For additional information focusing on terrorist financing, please
refer to the Department of State’s Country Reports on Terrorism,
which can be found here: http://www.state.gov/j/ct/rls/crt/
Do Financial Institutions engage in currency transactions related
to international narcotics trafficking that include significant
amounts of US currency; currency derived from illegal sales in the
U.S.; or that otherwise significantly affect the U.S.: NO
Criminalization of Money Laundering:
“All serious crimes” approach or “list” approach to predicate
crimes: Combination approach
Legal persons covered: criminally: YES civilly: YES
Know-your-customer (KYC) rules:
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES
KYC covered entities: Banks, finance companies, insurance
companies and insurance brokerage companies, pension fund
financial institutions, securities companies, investment managers,
providers of money remittance, and foreign currency traders
Suspicious Transaction Reporting (STR) Requirements:
Number of STRs received and time frame: 16,054 from January
through October 2011
Number of CTRs received and time frame: 1,412,769 from
January through October 2011
STR covered entities: Banks, financing companies, insurance
companies and insurance brokerage companies, pension fund
financial institutions, securities companies, investment managers,
custodians, trustees, postal services as providers of fund transfer
services, foreign currency changers (money traders), providers of
payment card services, providers of e-money or e-wallet services,
cooperatives doing business as savings and loan institutions,
pawnshops, commodity futures traders, money remitters, property
companies and agents, car dealers, dealers of precious stones
and jewelry/precious metals, art and antique dealers, and auction
houses
Money Laundering Criminal Prosecutions/Convictions:
Prosecutions: Not available
Convictions: Four from January through October 2011
Records exchange mechanism:
With U.S.: MLAT: NO Other mechanism: YES
With other governments/jurisdictions: YES
Indonesia is a member of the Asia/Pacific Group on Money
Laundering (APG), a Financial Action Task Force (FATF)-style
regional body. Its most recent mutual evaluation can be found
here: http://www.apgml.org/documents/docs/17/Indonesia%
20MER2_FINAL.pdf
Enforcement and implementation issues and comments:
In October 2010, the Government of Indonesia (GOI) enacted a
new AML law that partially complies with international standards.
Among other improvements, the law expands the list of agencies
permitted to conduct money laundering investigations, gives the
independent financial intelligence unit (FIU), PPATK, more
authority to examine suspicious financial transactions, and
increases some criminal penalties for money laundering offenses.
Personnel in both the executive and judicial branches should
receive more training to effectively implement and enforce the
expanded provisions of the AML law.
Indonesia’s PPATK is a dynamic and effective FIU that works
closely with the Central Bank to oversee and implement Indonesia’
s anti-money laundering regime. PPATK is well-funded and has
an experienced and effective leadership team in place. The
October 2010 AML legislation, however, has taxed the institution’s
capacity and PPATK will need a significant increase in staff to
meet its responsibilities under the law. In an effort to place some
of the legal burden on industry and bank partners, PPATK will
open three anti-money laundering centers in different regions of
Indonesia to serve as resource centers for organizations that
must comply with the new regulations.
Despite a stated high-level commitment to the action plan
developed to address some of the persistent gaps in its AML/CFT
legislation, the GOI has not met its projected timeframes.
Essential draft CFT legislation will not be submitted to parliament
until at least early 2012, more than a year later than originally
expected. Passage may be further delayed by disagreements
over various provisions, including those addressing forfeiture of
unexplained wealth and new reporting requirements for religious
institutions.
Indonesia continues to lack an effective mechanism to implement
UNSCRs 1267 and 1373. The October 2010 AML legislation only
provides for the temporary suspension of terrorist assets linked to
the UN list of designated terrorists and terrorist organizations and
does not allow for an immediate and ongoing freeze. Corruption,
particularly within the police ranks, impedes effective
investigations and prosecutions. Prosecutors and judges should
be given additional training on tracing and documenting financial
flows and presenting this evidence convincingly in court.
____________________________________________________
US State Dept Narcotics Report 2012 (introduction):
Indonesia faces continuing challenges in combating drug
production, trafficking, and internal drug use. Provisions of
Indonesia’s new National Narcotics Law approved in October
2009 have provided the Indonesian National Narcotics Board
(BNN) with increased resources and new mandates in the areas
of enforcement, demand reduction, and treatment of drug users.
However, the Government of Indonesia (GOI) still faces major
future challenges, especially in combating a growing use of
methamphetamines by Indonesian youth.
As of mid-2011, Indonesia had a population of approximately 4.1
million drug abusers (ca. 2 percent of Indonesia’s population), an
increase of roughly 500,000 since 2009. During a September
2011 International Drug Enforcement Conference in Bali, the BNN
Director stated that crime associated with drugs increased by 67
percent during the first six months of 2011 compared to the
previous six months. The BNN Director added that, while drug
usage has typically been associated with the country’s larger
cities, it is now spreading to smaller villages in many parts of the
archipelago. He also commented that 80 percent of the country’s
drug addicts are between the ages of 15 and 39 years, reflecting
the growing use of methamphetamines by young Indonesians.
The growing demand for methamphetamines, ecstasy, heroin,
and ketamine is reflected in higher seizure rates and higher street
prices in Indonesia than in most other Southeast Asian countries.
Most methamphetamine, heroin, and associated precursors still
come from Iran, Afghanistan, Pakistan, China, Thailand, Taiwan,
and India. However, small domestic laboratories, often located in
residences, produce a significant and growing amount of
methamphetamine and ecstasy. Typically the labs are run by
Indonesian drug syndicates or have an ethnic Chinese connection.
Most foreign drug smugglers caught with methamphetamine are
associated with Iranian, West African/Nigerian, or Malaysian drug
syndicates. Because Indonesian drug prices are high relative to
other Southeast Asian countries, the Indonesian market offers a
high profit margin as an added incentive to increase smuggling
operations into the country. For example, methamphetamine can
command a street value more than 10 times its cost in Iran.
Drugs smuggled into Indonesia typically transit Malaysia,
Singapore, Thailand, or arrive directly on flights originating from
Iran, Turkey, and other travel hubs in South Asia and the Middle
East. Methamphetamine and associated precursors originating
from China, Hong Kong, or Taiwan are brought in via ship. The
April 2011 seizure of 17.9 kilograms of Iranian-sourced
methamphetamine concealed in a shipping container in Jakarta’s
port of Tanjung Priok and the increased frequency of air cargo
shipments containing narcotics represent two of the more
significant drug trends during the past year. There has also been
a tangible increase in illegal ketamine importation over the past
year. Most of the ketamine originates in India, but small amounts
from China have also been detected. Cannabis seizures have
been gradually declining.
For Full report, click here
____________________________________________________
US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 2)
Indonesia is a major source country, and to a much lesser extent
a destination and transit country for women, children, and men
who are subjected to sex trafficking and forced labor. Each of
Indonesia’s 33 provinces is a source and destination of trafficking,
with the most significant source areas being Java, West
Kalimantan, Lampung, North Sumatra, and South Sumatra. A
significant number of Indonesian migrant workers face conditions
of forced labor and debt bondage in more developed Asian
countries and the Middle East – particularly Malaysia, Saudi
Arabia, Singapore, Kuwait, Syria, and Iraq. The number of
Indonesians seeking work abroad remains very high, with an
estimated 6.5 million to 9 million Indonesian migrant workers
worldwide, including 2.6 million in Malaysia and 1.8 million in the
Middle East. An estimated 69 percent of all overseas Indonesian
workers are female. IOM and a leading Indonesian anti-trafficking
NGO estimates that 43 to 50 percent – or some 3 to 4.5 million – of
Indonesia’s expatriate workforce are victims of conditions
indicative of trafficking. Of 3,840 trafficking victims IOM and the
Indonesian government identified upon their return from work
overseas, 90 percent were female and 56 percent had been
exploited in domestic work. According to IOM, a total of 82 percent
of victims identified in 2010 had been trafficked abroad; 18
percent were trafficked within Indonesia. During voluntary
interviews, these Indonesian trafficking victims reporting
experiencing the following forms of abuse, all conducive to
trafficking: withheld salary (85 percent); excessive working hours
(80 percent); total restriction of movement (77 percent); verbal or
psychological abuse (75 percent); and confiscation of travel
documents (66 percent). The number of Indonesian women who
are raped while working as domestic workers appears to be on
the rise. Based on a 2010 survey, a respected Indonesian NGO
noted that during the year 471 Indonesian migrants returned from
the Middle East pregnant as the result of rape, and an additional
161 returned with children who had been born in the Middle East.
Half of the victims of trafficking within the country were children,
while 70 percent of victims trafficked abroad were adults.
According to IOM, labor recruiters, both legal and illegal, are
responsible for more than 50 percent of the Indonesian female
workers who experience trafficking conditions in destination
countries. Some recruiters work independently, others for
recruitment labor companies called PJTKIs (which include both
legal and illegal companies). Some PJTKIs operate similar to
trafficking rings, leading both male and female workers into debt
bondage and other trafficking situations. These recruitment
brokers often operate outside the law with impunity and some
PJTKIs use ties to government officials or police to escape
punishment. There are reports of workers recruited for overseas
work by PJTKIs being confined involuntarily for months in
compounds – ostensibly for training and processing – prior to their
deployment, accumulating debts that make them vulnerable to
debt bondage. Licensed and unlicensed companies used debt
bondage, withholding of documents, threats of violence, and
confinement in locked premises for extended periods to keep
Indonesian migrants in situations of forced labor.
Indonesian women migrate to Malaysia, Singapore, and the
Middle East and are subsequently subjected to forced
prostitution; they are also subjected to forced prostitution and
forced labor in Indonesia. According to the Director General for
the Development of Tourist Destinations, an estimated 40,000 to
70,000 Indonesian children have been exploited in prostitution
within the country. Children are trafficked internally and abroad
primarily for domestic servitude, forced prostitution, and cottage
industries. Many of these trafficked girls work 14-16 hours a day
at very low wages, often under perpetual debt due to pay
advances given to their families by Indonesian brokers. Debt
bondage is particularly pronounced among sex trafficking victims,
with an initial debt of some $600 to $1,200 imposed on victims;
given an accumulation of additional fees and debts, women and
girls are often unable to escape this indebted servitude, even
after years in prostitution. Sixty percent of children under 5 years
old do not have official birth certificates, putting them at higher
risk for trafficking. Traffickers employ a variety of means to attract
and control victims, including promises of well-paying jobs, debt
bondage, community and family pressures, threats of violence,
rape, false marriages, and confiscation of passports.
A trend of recruitment of Indonesian migrant workers in Malaysia
for Umrah, a religious pilgrimage to Mecca continued during the
year; once in the Saudi Kingdom, Indonesian migrants are
trafficked to other points in the Middle East. A greater number of
Indonesian girls were recruited into sex trafficking through Internet
social networking media during the year. Traffickers also resorted
to outright kidnapping of girls and young women for sex trafficking
within the country and abroad. More than 25 sex trafficking victims
from Uzbekistan were identified in 2010, and there were reports of
victims from China, Thailand, other Central Asian countries, and
Eastern Europe exploited in Indonesia.
Internal trafficking is also a significant problem in Indonesia, with
women and girls exploited in domestic servitude, commercial
sexual exploitation, and in forced labor in rural agriculture, mining,
and fishing. Many victims were originally recruited with offers of
jobs in restaurants, factories, or as domestic workers before they
were coerced into prostitution. Child sex tourism is prevalent in
most urban areas and tourist destinations, such as Bali and Riau
Island. Some traffickers continued to forge partnerships with
school officials to recruit young men and women in vocational
programs for forced labor on fishing boats through fraudulent
“internship” opportunities. In April 2011, the government
established the National Coalition for the Elimination of
Commercial Sexual Exploitation of Children at the University of
Indonesia as a first step to addressing the problem.
The Government of Indonesia does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. During the year, the
government undertook efforts to improve coordination and
reporting of its anti-trafficking efforts. However, the government
did not enact necessary migrant worker legislation or apply
sufficient criminal sanctions to labor recruiters who subject
Indonesian migrants to labor trafficking. Moreover, the
government did not demonstrate vigorous efforts to investigate,
prosecute, and criminally punish law enforcement officials
complicit in human trafficking, and this remained a severe
impediment to the government’s and NGOs’ anti-trafficking efforts.
During the year, the Indonesian government undertook a number
of reforms that significantly improved the coordination and
effectiveness of the 19 ministries and agencies involved in
addressing human trafficking. The government clarified the role of
the National Agency for Placement and Protection of Indonesian
Overseas Workers (BNP2TKI) in implementing the 2004 migrant
labor law (Law No. 39), which created the agency. It also enacted
a new immigration law that provides additional tools with which to
fight the complicity of law enforcement officials in human
trafficking and smuggling, and advanced draft legislation to
protect migrant workers, including trafficking victims, more
effectively. Recognizing the high vulnerability of female migrant
workers in some receiving countries, the Indonesian government
imposed a ban on its certification of additional Indonesian female
migrants going to Saudi Arabia and Jordan; it continued an earlier-
imposed ban on female migrants going to Malaysia.
For full report click here
____________________________________________________
US State Dept Terrorism Report 2010
Overview: In 2010, the Indonesian government continued to build
counterterrorism capacities, successfully prosecuted a number of
terrorists, and strengthened legislative efforts to counter terrorist
financing. A new National Counterterrorism Agency (BNPT) was
formally established on July 16 and President Yudhoyono swore
in retired Police Inspector General Ansyaad Mbai as its head on
September 7.
In February 2010, Indonesian police discovered a large
paramilitary terrorist training camp in Aceh. Officials identified at
least eight terrorist factions involved in the terrorist training camp.
The factions included militants who trained in Mindanao in the
southern Philippines, graduates of terrorist training camps in
Afghanistan and Pakistan, students, government workers, and
released terrorist convicts who had undergone de-radicalization
programs while in the Indonesian corrections system. Police
believed the Aceh-based terrorist group intended to target
Indonesian government officials, including President Susilo
Bambang Yudhoyono.
The success of police actions following the breakup of the Aceh
training camp, however, continued to demonstrate increased
police capacities, including successful operations carried out with
a minimum loss of life to both terrorists and civilians, though some
terrorists were killed during police raids. Police captured over 120
terrorists associated with the Aceh training camp, including
Abdullah Sunata, a leader of the radical group Kompak, known for
its involvement in ethnic conflicts in Poso and Ambon, and Abu
Tholut, a bomb maker believed to have funded the Aceh terrorist
training camp. In addition, the death of a third well-known terrorist,
Dulmatin, an electronics expert and bomb maker who received al-
Qa’ida training in Afghanistan and was wanted in connection to
the 2002 Bali bombing, brought to an end an intensive
international manhunt across Southeast Asia.
The number of corrections recidivists involved in the Aceh training
camp concerned the Indonesians. At least 18 recidivists were
either killed or captured in police actions connected to the camp.
The Government of Indonesia recognized that the high rate of
recidivism was one of a number of concerns related to the
Indonesian prison system that needed to be addressed. Prison
sector issues also included rehabilitative capacity, security
procedures, organizational structure, and training. Evidence that
terrorists within and outside of the corrections system (including
Dulmatin) were in contact with each other and were able to further
develop terrorist networks while incarcerated further highlighted
the need for broad prison reform.
2010 Terrorist Incidents: On the heels of successful police
actions, militants conducted retribution strikes against police
stations. On March 12, terrorists associated with the Aceh training
camp attacked a police outstation in Aceh. On September 22,
after a series of police actions in North Sumatera, 12 heavily-
armed men on six motorcycles killed three police officers in a
heavy-arms attack on a sub-district police station.
Indonesian law enforcement authorities believe terrorists
conducted a series of bank robberies to finance terrorist activities.
The most brazen bank robbery took place midday August 18
when 16 heavily armed robbers robbed a bank in the Medan
central commercial district. The robbers killed a police officer and
wounded two bank security guards.
Legislation and Law Enforcement: While Indonesia’s Terrorism
and Transnational Crime Task Force has a successful track
record in prosecuting terrorism cases, the 2010 arrests linked to
terrorist camps in Aceh revealed a limitation in Indonesia’s ability
to counter terrorism; nothing in Indonesian law directly
criminalizes participation in terrorist training camps. The Ministry
of Law and Human Rights formed an inter-agency working group
to draft amendments to Indonesia’s 2003 Terrorism law to
address deficiencies in the current law. In addition, draft
legislation to address the use of intelligence information in
terrorism cases was also in progress.
One major development in terms of pending legislation was the
formal establishment of the BNPT. On July 16, Presidential
Decree Number 46/2010 formally established the BNPT as a free-
standing agency. The new agency replaced the Anti-Terrorism
Coordinating Desk, which was housed in the Coordinating Ministry
for Political, Legal, and Security Affairs. On September 7,
President Yudhoyono swore in retired Police Inspector General
Ansyaad Mbai as the head of the BNPT. Mbai reported directly to
the President and attended relevant cabinet sessions. However,
the Coordinating Ministry for Political, Legal, and Security Affairs
retained oversight over the BNPT, similar to its oversight over
other ministries or agencies, including the Foreign Ministry,
National Intelligence Agency (BIN), and the Indonesian National
Police. The BNPT’s organizational structure contained a
secretariat responsible for administration and program
coordination, three deputies responsible for prevention,
protection, and de-radicalization efforts; operations and
capabilities; and international cooperation.
In addition, the Indonesian National Police’s (INP)
counterterrorism unit, Special Detachment 88, was separated
from the INP’s Criminal Investigation Unit and placed under the
BNPT deputy responsible for operations and capabilities, but
remained under the direct command of the national police chief. In
a move to consolidate their efforts, provincial Detachment 88 units
were abolished and replaced with 10 regional units.
Prosecutions: In 2010, the Attorney General’s Office Task Force
on Terrorism and Transnational Crime (SATGAS) secured
convictions of 11 terrorists connected with the 2009 bombings of
the J.W. Marriott and Ritz-Carlton hotels in Jakarta. A twelfth
defendant, Saudi national Al Khalil Ali, was charged with financing
the July 17, 2009 twin Jakarta hotel bombings under Indonesia’s
fledgling terrorist finance law. Ali was acquitted of the terrorism
charge on June 28, 2010, but found guilty of immigration
violations and sentenced to 18 months imprisonment.
SATGAS prosecutors have developed extensive experience
prosecuting terrorism cases, which are brought under a
specialized terrorism law with different procedures than ordinary
criminal cases. SATGAS prosecutors have developed long-term,
close professional relationships with the specialized police unit,
Detachment 88, which investigates Indonesia’s terrorism cases.
This has led to a new criminal model in Indonesia – police and
prosecutors working together on cases from the onset instead of
prosecutorial engagement beginning after a police investigation
has concluded. At the end of 2010, SATGAS was currently
prosecuting more than 70 defendants associated with the Aceh
training camp.
Border Security: Since 2006, a photo and 10 fingerprints have
been taken for all passport applicants. This information was sent
back to a central site for biometric checking which ostensibly must
be completed before a passport can be issued. However,
duplicative passports with false identities were easily obtainable.
This systemic weakness was highlighted when police discovered
that Muhammad Jibriel Abdur Rahman, aka Muhammad Ricky
Ardhan, who was sentenced in 2010 to five years in jail for his role
in the July 17, 2009 Jakarta bombings, was found to possess one.
In addition, when terrorist Dulmatin was killed in March 2010 press
reports state he had an Indonesian passport issued by the East
Jakarta Immigration Office in the name of Yahya Ibrahim. The
Government of Indonesia has noted the weaknesses in official
documentation controls and has been working to address the
issue.
Countering Terrorist Finance: Indonesia demonstrated concrete
progress in improving its Anti-Money Laundering/Countering
Financing of Terrorism (AML/CTF) regime. In February, the
government committed to work with the Financial Action Task
Force and the Asia/Pacific Group (APG) to address remaining
AML/CTF deficiencies.
On October 22, President Yudhoyono signed Law No. 8 of 2010
on the Prevention and Eradication of the Crime of Money
Laundering, which will help Indonesia counter terrorist finance and
transnational crime. The legislation permits rapid freezing and
seizure of assets and bank accounts, which will make it easier for
Indonesia to comply with UNSCRs 1267 and 1373 and bolster the
ability of police and prosecutors to pursue individuals who provide
critical financial support to terrorists. This law expanded the
number of agencies permitted to conduct money laundering
investigations; increased the ability of the independent Financial
Intelligence Unit (PPATK) to examine suspicious financial
transactions; expanded institutions authorized to obtain results of
PPATK analysis or examination of transactions; created a
streamlined mechanism to seize and freeze criminal assets;
expanded the entities which must file reports with PPATK; and
increased some criminal penalties for money laundering offenses.
The law designated non-financial businesses, in addition to
Indonesian banks and providers of financial services, which were
required to report suspicious transactions to PPATK. Throughout
the remainder of 2010, the PPATK led a government team
preparing regulations and guidelines to implement the new law.
The government was in the process of developing a
comprehensive bill on countering terrorist financing at year’s end.
In addition, the Central Bank issued new regulations, effective
December 1, which apply to all rural banks and require more
extensive provisions for due diligence for high-risk customers and
politically exposed persons, and checks against the Central Bank’
s Terrorist List, based on data published by the UN.
Regional and International Cooperation: Indonesia signed the
Beijing Convention on the Suppression of Unlawful Acts Relating
to International Civil Aviation and the Beijing Protocol to the
Convention for the Suppression of Unlawful Seizure of Aircraft at
the conclusion of an International Civil Aviation Organization
diplomatic conference in September.
Countering Radicalization and Violent Extremism: While Indonesia’
s new BNPT has stated its intent to incorporate counter-
radicalization into its overall counterterrorism strategy, civil society
organizations continued to take the lead in developing and
implementing counter-radicalization programs at the local level.
For example, the Association for Victims of Terrorism Bombings in
Indonesia, which includes family members of victims of terrorism in
Indonesia, worked to counter violent extremism through public
outreach events held at schools and for communities in Indonesia.
The corrections system lacked formal rehabilitation and
reintegration programs for all prisoners, including terrorists. As
with counter-radicalization, the BNPT stated it intended to play a
more significant role in de-radicalization efforts moving forward.
____________________________________________________
Links:
Worldwide AML Legislation (International Bar Association)
Indonesian Financial Transaction Reports and Analysis Centre
(INTRAC)
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*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.
For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -
R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV
Please also note that any risk assessment should take into consideration all
follow-up reports.
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.
For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -
R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV
Please also note that any risk assessment should take into consideration all
follow-up reports.
| INDONESIA |
| KnowYourCountry |
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| Last Updated: 16 April 2012 |