The AML CFT Framework was built to support the SPI Vision 2025 and prevent money laundering, terrorism financing, and funding for the proliferation of weapons of mass destruction that pose various risks, including:
Sectoral Risk Assessment (SRA)
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Bank Indonesia has been conducted the risk assessment of Money Laundering (ML), Terrorist Financing (TF), and Financing of Proliferation of Weapons of Mass Destruction (PFWMD) in the sector of Non-Bank Payment Service Providers and Non-Bank Money Changers. The assessment is based on geographic, customer, products and services, and delivery channels. The risk assessment is outlined in the Sectoral Risk Assessment (SRA) which refers to the National Risk Assessment (NRA) on ML, TF, and PFWMD. The purpose of the SRA adjustment as follows:
- Identifying and analysing the threats, vulnerabilities and consequences of money laundering, terrorist financing and financing of proliferation of weapons of mass destruction;
- Identifying, analysing and evaluating various risks associated with money laundering, terrorist financing and financing of proliferation of weapons of mass destruction based on risk mapping of customer profiles (individual and corporate), regions, products and services as well as delivery channels;
- Identifying and analysing new and/or emerging threats posed by money laundering, terrorist financing and financing of proliferation of weapons of mass destruction; and
- Formulating strategy measures to mitigate the risk of money laundering, terrorist financing and financing of proliferation of weapons .
NRA on Money Laundering publication can be
downloaded here
NRA on Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction publication can be
downloaded here
SRA publications can be
downloaded here
AML CFT Policy
As a Supervisory and Regulatory Bodies (LPP), Bank Indonesia has issued Bank Indonesia Regulation (PBI) No. 19/10/PBI/2017 concerning the Implementation of Anti-Money Laundering and Countering Terrorism Financing for Non-Bank Payment System Service Providers and Non-Bank Money Changers (PBI AML CFT).
The provisions contained in PBI AML CFT became effective in September 2017, targeting Non-Bank Payment System Service Providers as well as Non-Bank Money Changers. The PBI also stipulates the AML CFT requirements specific to payment system service providers and Money Changers as follows:
- tasks and responsibilities of the directors and active supervision of the Board of Commissioners;
- policies and written procedures;
- risk-management processes;
- human resources management; and
- internal control system.
In compiling the PBI AML CFT, BI adopts various provisions, including:
- FATF 40 Recommendations;
- Act No. 8 of 2010 concerning the Prevention and Eradication of Money Laundering (ML Act);
- Act No. 9 of 2013 on the Prevention and Eradication of Terrorism Financing (TF Act).
Beside issuing the PBI AML CFT, Bank Indonesia also issues other BI Regulations that refer to the PBI AML CFT, including:
Payment System regulatory reform as part of the Indonesia Payment System Blueprint (BSPI) 2025 also regulates AML CFT obligations for Non-Bank Payment Service Provider and Non-Bank Money Changers, through the issuance of several PBIs as follows:
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PBI No. 22/23/PBI/2020 concerning Payment System
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PBI No. 23/6/PBI/2021 concerning Payment Service Providers
- PBI No. 23/7/PBI/2021 concerning Payment System Infrastructure Provider.
Bank Indonesia also issued technical guidelines derived from the PBI AML CFT, including:
- Guidelines on the implementation of Risk Based Approach of AML CFT (RBA);
- Guidelines on Know Your Customer (Customer Due Diligence) for Non-Bank Payment System Service Providers and Non-Bank Money Changers.
- Guidelines on the implementation of immediate blocking of fund owned by individuals or corporations the identities of which are listed in the List of Suspected Terrorists and Terrorist Organizations (DTTOT);
- Guidelines on the implementation of immediate blocking of fund owned by individuals or corporations the identities of which are listed in the List of Funding of Proliferation of Weapons of Mass Destruction;
In order to optimize efforts to mitigate ML, TF, and PFWMD, Bank Indonesia has compiled a Typology Study of ML, TF, and PFWMD for Non-Bank Payment Service Provider and Non-Bank Money Changers. This study is expected to increase the awareness and become a risk mitigation guideline for Non-Bank Payment Service Providers, Non-Bank Money Changers, Law Enforcement Agencies (APH), and other relevant authorities to identify the typology undertaken by the perpetrator
s in the context of mitigating money laundering, terrorism financing, and proliferation of weapons of mass destruction.
Typology Study of
ML, TF, and PFWMD for Non-Bank Payment Service Provider and Non-Bank Money Changers 2021 can be
downloaded here.
Technical Guidelines AML CFT
Risk Based Approach (RBA)
In accordance with FATF Recommendation No. 1, Providers must identify and understand the risks of money laundering and terrorism financing covering geographic, customer, products and services, and delivery channels. As well as referring to the PBI AML CFT, Risk Based Approach (RBA) is used to improve the quality of supervision in order to prevent misuse of Non-Bank Payment System Service Providers and Non-Bank Money Changers as media for money laundering and / or terrorism financing.
The application of a Risk Based Approach (RBA) includes:
- Offsite and onsite risk-based supervision with risk ranking monitoring tools and RBA working papers;
- The Providers uses the RBA of AML CFT to conduct risk and operational assessments.
Guidelines for the Implementation of Risk Based Approach (RBA) for Non-Bank Money Transfer Services Providers and Non-Bank Money Changers can be
downloaded here
Guidelines for the Implementation of Risk Based Approach (RBA) for Non-Bank E-Money and E-Wallet Issuers also Non-Bank Issuers of Card Based Payment Instrument can be
downloaded here
Guideline on Know Your Customer (Customer Due Diligence) for Non-Bank Payment System Services Providers and Non-Bank Money Changers
In general, the procedures and mechanisms of Customer Due Diligence (CDD) implementation are regulated in accordance with the PBI AML CFT. To facilitate greater understanding amongst Service Providers in terms of meeting and conducting CDD as mandated by the PBI AML CFT, Bank Indonesia published the CDD guidelines for Non-Bank Payment System Providers and Non-Bank Money Changers.
Some highlights in the CDD guidelines are as follows:
- CDD guidelines are a reference that must be followed by Providers in implementing the CDD process for Service Providers, Service Users and beneficial owners, both conventional and electronic CDD (e-CDD).
- The application of e-CDD is the same as the application of conventional CDD, namely Simple CDD, Standard CDD, and Enhanced Due Diligence (EDD), by carrying out 4 (four) stages, namely identification, verification, on-going due diligence, and understanding the intentions and the purpose of the relationship.
- Providers implementing e-CDD, in principle, must comply with the rules regarding CDD implementation that have been stipulated in the PBI AML CFT, including applying e-CDD to Beneficial Owners.
- In case Service Provider carries out one of the e-CDD processes, the implementation of the process shall be carried out with due observance of the implementation of the e-CDD process which is stated in this Guideline.
Guidelines of Know Your Customer/Customer Due Diligence (CDD) Principles for Non-Bank Payment System Service Provider and Non-Bank Money Changer can be
downloaded here.
List of Suspected Terrorists and Terrorist Organizations (DTTOT)
Based on Act No. 9 of 2013 concerning the Prevention and Eradication of Terrorism Financing, terrorism financing is defined as the direct or indirect use of funds for terrorist acts. The scope of terrorism financing includes direct and indirect actions to make available, accumulate, provide or lend funds to terrorists or for terrorist acts, including the proceeds of crime or legally obtained wealth.
Suspicious Financial Transactions on TF are:
- Financial transactions with the intent to be used and / or which are known to be used to commit terrorism; or
- Transactions involving Persons or Corporations whose name is listed in DTTOT.
Legal Provisions Relating to the DTTOT
- Act No. 9 of 2013 on the Prevention and Eradication of Terrorism Financing (TF Act);
- Joint Regulation of the Supreme Court, the Indonesian Minister of Foreign Affairs, the Chief of Police, the Head of the National Agency for Counterterrorism (BNPT) and Head of the Financial Transaction Reporting and Analysis Center (PPATK) on the Inclusion of Identity of Persons and Corporations in DTTOT and Immediate Blocking of the Funds of Persons or Corporations whose name is Listed in DTTOT;
- Bank Indonesia Regulation (PBI) No. 19/10/PBI/2017 concerning the Implementation of Anti-Money Laundering and Countering Terrorism Financing for Non-Bank Payment System Service Providers and Non-Bank Money Changers (PBI AML CFT).
In accordance with Financial Action Task Force (FATF) Recommendation No. 6, Bank Indonesia forwarding the Indonesian National Police letter related to DTTOT information and blocking orders to all Non-Bank Payment System Service Providers and Non-Bank Money Changers, followed up with the obligation to immediately blocking all funds owned or controlled, by any person or corporation listed in the DTTOT. Guidelines on the implementation of immediate blocking of fund owned by individuals or corporations the identities of which are listed in the list of suspected terrorists and terrorist organizations can be downloaded
here
The complete list of Suspected Terrorists and Terrorist Organizations (DTTOT) and the Immediate Blocking of Funds owned by Persons or Corporations Listed in DTTOT can be downloaded
here
DTTOT Flow of Information
UNSC; Ministry of Foreign Affairs; National Police; Central Jakarta District Court; Bank Indonesia; Payment System Service Providers/Money Changers
DTTOT Flow of Information;
Flow of Information from Service Providers
List of Financing the Proliferation of Weapons of Mass Destruction (WMD)
Based on the Joint Regulation of the Minister of Foreign Affairs of the Republic of Indonesia, Chief of the National Police of the Republic of Indonesia, Chairperson of the Indonesian Financial Transaction Reports and Analysis Centre (INTRAC) and Chairperson of the Nuclear Energy Supervisory Agency, WMD proliferation is defined as the proliferation of nuclear, biological and chemical weapons using the proceeds of crime or wealth obtained legally.
Legal Provisions Relating to the Proliferation of Weapons of Mass Destruction
- Joint Regulation of the Minister of Foreign Affairs of the Republic of Indonesia, Head of the Indonesian National Police, Head of the Center for Reporting and Analysis of Financial Transactions, and Head of the Nuclear Energy Supervisory Agency on Inclusion of Identity of Persons and Corporations in the List of Funds for the Proliferation of Weapons of Mass Destruction and Blocking and Accidental Ownership of Owned Funds or Corporations that are listed on the list of funding for the proliferation of weapons of mass destruction.
- Bank Indonesia Regulation (PBI) No. 19/10/PBI/2017 concerning the Implementation of Anti-Money Laundering and Countering Terrorism Financing for Non-Bank Payment System Service Providers and Non-Bank Money Changers (PBI AML CFT).
In accordance with Financial Action Task Force (FATF) Recommendation No. 7, Bank Indonesia transmits information on the proliferation of weapons of mass destruction from PPATK to the providers and is followed up with the obligation to immediately block all funds owned or controlled, directly or indirectly, by persons or Corporations based on the Register of Proliferation of Weapons of Mass Destruction. Guidelines on the implementation of immediate blocking of fund owned by individuals or corporations the identities of which are listed in the list of funding of proliferation of weapons of mass destruction can be downloaded
here
The complete List of Proliferation of Weapons of Mass Destruction Financing can be downloaded
here
Flow of Information concerning Financing the Proliferation of Weapons of Mass Destruction
UNSC; Ministry of Foreign Affairs; Indonesian Financial Transaction Reports and Analysis Centre (INTRAC); Bank Indonesia; Payment System Service Providers/Money Changers
WMD Proliferation Flow of Information;
Flow of Information from Service Providers
Information concerning the List of Suspected Terrorists and Terrorist Organisations (DTTOT) and List of Financing the Proliferation of Weapons of Mass Destruction (WMD) is available for download.