Bank Indonesia has ​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 .
In line with the publication of the SRA for the Non-Bank Payment Service Providers and Non-Bank Money Changers sectors by Bank Indonesia, the Indonesian Financial Intelligence Unit (PPATK) has also published the Sectoral Risk Assessment on Money Laundering (ML) and Terrorist Financing (TF) related to Cybercrime. Taking into account the findings of these SRAs, Reporting Parties are expected to enhance their vigilance and further strengthen the detection and submission of Suspicious Transaction Reports (STRs).​​​​​
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
SRA on Money Laundering (ML) and Terrorist Financing (TF) related to Cybercrime can be downlo​aded 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).
PBI AML CFT can be
downloaded here
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:
-
PBI No. 22/23/PBI/2020 concerning Payment System
-
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 perpetrators
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.
