VZCZCXRO4444
RR RUEHCHI RUEHCN RUEHDT RUEHHM
DE RUEHJA #3140/01 3170834
ZNR UUUUU ZZH
R 130834Z NOV 07
FM AMEMBASSY JAKARTA
TO RUEHC/SECSTATE WASHDC 7020
RUEATRS/DEPT OF TREASURY WASHDC
RUEAWJB/DEPT OF JUSTICE WASHDC
INFO RUEHZS/ASSOCIATION OF SOUTHEAST ASIAN NATIONS
RUCPDOC/DEPT OF COMMERCE WASHDC
RUEHKO/AMEMBASSY TOKYO 1098
RUEHBJ/AMEMBASSY BEIJING 4472
RUEHBY/AMEMBASSY CANBERRA 1537
RUEHUL/AMEMBASSY SEOUL 4288
RUEAIIA/CIA WASHDC

UNCLAS SECTION 01 OF 07 JAKARTA 003140 
 
SIPDIS 
 
SIPDIS 
 
DEPT FOR INL, S/CT, EAP/MTS AND EEB/IFD/OMA 
TREASURY FOR FINCEN 
SINGAPORE FOR BAKER 
COMMERCE FOR 4430-BERLINGUETTE 
DEPARTMENT PASS FEDERAL RESERVE SAN FRANCISCO FOR FINEMAN 
 
E.O. 12598: N/A 
TAGS: KCRM EFIN KTFN SNAR ID
SUBJECT: INDONESIA - INCSR II, MONEY LAUNDERING AND FINANCIAL 
CRIMES 
 
REF: STATE 137250 
 
¶1. This report responds to reftel request for an anti-money 
laundering and financial crimes update for INCSR II. 
 
Background and Overview 
----------------------- 
 
¶2. Although neither a regional financial center nor an offshore 
financial haven, Indonesia is vulnerable to money laundering and 
terrorist financing due to a poorly regulated financial system, the 
lack of effective law enforcement and widespread corruption.  Most 
money laundering in the country is connected to non-drug criminal 
activity such as gambling, prostitution, bank fraud, piracy and 
counterfeiting, illegal logging and corruption.  Indonesia also has 
a long history of smuggling, facilitated by thousands of miles of 
un-patrolled coastline and a law enforcement system riddled with 
corruption.  The proceeds of these illicit activities are easily 
parked offshore and only repatriated as required for commercial and 
personal needs. 
 
¶3. Banks and other financial institutions now routinely question the 
sources of funds or require identification of depositors or 
beneficial owners.  Financial reporting requirements were put in 
place in the wake of the 1998 Asian financial crisis when the GOI 
became interested in controlling capital flight and recovering 
foreign assets of large-scale corporate debtors or alleged corrupt 
officials.   As a result of Indonesia's ongoing efforts to implement 
the reforms to its Anti-Money Laundering (AML) regime, the Financial 
Action Task Force (FATF) removed Indonesia from its list of 
Non-Cooperative Countries and Territories (NCCT) on February 11, 
2005 and subsequent special FATF monitoring on February 11, 2006. 
The removal of Indonesia from the NCCT list and special monitoring 
recognized a concerted, interagency effort supported by President 
Susilo Bambang Yudhoyono to further develop Indonesia's nascent AML 
regime. 
 
Laws and Regulations on Illicit Money Flows 
------------------------------------------- 
 
¶4. In April 2002, Indonesia passed Law No. 15/2002 Concerning the 
Crime of Money Laundering, Indonesia's anti-money laundering (AML) 
law, which made money laundering a criminal offense.  The law 
identifies 15 predicate offenses related to money laundering, 
including narcotics trafficking and most major crimes.  Law No. 
15/2002 established the PPATK to develop policy and regulations to 
combat money laundering and terrorist finance.  This law stipulated 
important provisions to enhance an anti-money laundering regime, 
such as: 
 
A) The criminalizing of money laundering activities; 
 
B) The obligation of Providers of Financial Services to submit 
Suspicious Transaction Reports (STR) and Cash Transaction Reports 
(CTR); 
 
C) Reporting, investigation, prosecution and justice for criminal 
offences of money laundering are exempted from the provisions of 
bank secrecy that are stipulated in Indonesia's Banking Law; 
 
D) Placed the burden of proof, that assets were not from criminal 
activities on the defendant (instead of the prosecution having the 
burden of proving that the assets were derived from criminal 
activities, the onus is on the criminal to prove that the source of 
funds is legitimate to 
purchase assets); 
 
E) Established the Financial Transactions Reports and Analysis 
Center (PPATK) as an independent agency with the duty and authority 
to prevent and eradicate criminal offences of money laundering; 
 
F) Established a clear legal basis for freezing and confiscating the 
proceeds of crime. 
 
Financial Transaction Reports and 
Analysis Center (PPATK) 
--------------------------------- 
 
JAKARTA 00003140  002 OF 007 
 
 
 
¶3. PPATK, fully functional since October 2003, continues to make 
steady progress in developing its human and institutional capacity. 
The PPATK receives, maintains, analyzes, and evaluates currency and 
suspicious financial transactions, provides advice and assistance to 
relevant authorities, and issues publications.  Total STRs obtained 
by PPATK from providers of financial services and total reporting 
parties develop from year to year aggressively.  As of July 2007, 
the PPATK has received approximately 3,385 suspicious transactions 
reports (STRs) from 181 institutions.  The volume of STRs has 
increased from an average of 10 per month in 2002, to 484 per month 
in 2007. The agency also reported that it had received over 3.6 
million cash transaction reports (CTRs). 
 
¶4. As of July 2007, there were 493 cases referred by PPATK to the 
Police and the AGO.  Thus far, 32 cases/defendants have been 
successfully prosecuted, which seven of them were charged by money 
laundering offence.  We believe the figure is a positive signal to 
produce timely outcomes of prosecutions for money laundering 
offenses: one case involving terrorism; 24 cases involving bank 
fraud and/or corruption in connection with money laundering; and 
eleven final judgments for money laundering offenses. 
 
¶5. Indonesia's Anti-Money Laundering and Counter Terrorism Finance 
(CTF) Donors' Coordination Group, co-chaired by the PPATK and the 
Australian Agency for International Development (AUSAID), has become 
a model for AML/CTF donors' coordination groups in other countries. 
Since Indonesia's removal form the NCCT list, donors and the 
Government of Indonesia (GOI) have placed greater emphasis on more 
practical training; technical and capacity building assistance for 
the non-bank financial sector, police, prosecutors and judges; cash 
smuggling; and regulation of charities and money changers.  The Asia 
Pacific Group (APG) in July 2006 named PPATK Chairman Yunus Husein 
as a co-chair of the regional FATF style organization for a two-year 
term.  In November 2006, Indonesia hosted the annual APG Typologies 
Workshop. 
 
¶6. The PPATK is actively pursuing broader cooperation with relevant 
GOI agencies. The PPATK has signed ten domestic memoranda of 
understanding (MOUs) to assist in financial intelligence information 
exchange with the following entities: Attorney General's Office 
(AGO), Bank Indonesia (BI), the Capital Market Supervisory Agency 
(BAPEPAM), the Ministry of Finance Directorate General of Financial 
Institutions, the Directorate General of Taxation, DGCE, the 
Ministry of Forestry Center for International Forestry Research, the 
Indonesian National Police, the Supreme Audit Board (BPK), and the 
Corruption Eradication Committee.   Government through the 
Presidential Decree No. 1/2004 established National Coordinating 
Committee on the prevention and eradication of the crime of money 
laundering as cooperating forum among relevant institutions in 
handling money laundering and terrorist financing. 
 
Crime of Money Laundering 
------------------------- 
 
¶7. In September 2003, Parliament passed Law No. 25/2003 amending Law 
No. 15/2002 Concerning the Crime of Money Laundering that addressed 
many FATF concerns. Amending Law No. 25/2003 provides a new 
definition of the crime of money laundering making it an offense for 
anyone to deal intentionally with assets known or reasonably 
suspected to constitute proceeds of crime with the purpose of 
disguising or concealing the origins of the assets, as seen in 
Articles 1(1) and 3.  The amendment removes the threshold 
requirement for proceeds of crime and expands the definition of 
proceeds of crime to cover assets employed in terrorist activities. 
Article 1(7)(c) expands the scope of regulations requiring STRs to 
include attempted or unfinished transactions.  Article 13(2) 
shortens the time to file an STR to three days or less after the 
discovery of an indication of a suspicious transaction. 
 
¶8. Article 17A makes it an offense to disclose information about the 
reported transactions to third parties, which carries a maximum of 
five years' imprisonment and a maximum of one billion rupiah 
(approximately $110,000). Articles 44 and 44A provide for mutual 
legal assistance with respect to money laundering cases, with the 
ability to provide assistance using the compulsory powers of the 
court. Article 44B imposes a mandatory obligation on the PPATK to 
 
JAKARTA 00003140  003 OF 007 
 
 
implement provisions of international conventions or international 
recommendations on the prevention and eradication of money 
laundering.  The GOI in March 2006 enacted Indonesia's first Mutual 
Legal Assistance (MLA) Law (No. 1/2006), establishing formal, 
binding procedures to facilitate MLA with other states. 
 
¶9. A proposed amendment to the law was submitted to the Parliament 
in October 2006.  If passed, it would require non-financial service 
businesses and professionals who potentially could be involved in 
money laundering -- such as car dealers, property companies, jewelry 
traders, notaries and public accountants -- to report suspicious 
transactions.   The current law requires only banks and financial 
service companies to report suspicious transactions.  The amendment 
also would include civil asset forfeiture and give more 
investigative powers to the PPATK, as well as the authority to block 
financial transactions suspected of being related to money 
laundering.  This would be the third amendment to the law. 
 
Know Your Customer 
------------------ 
 
¶10. As bank supervisor, Bank Indonesia (BI), the Indonesian Central 
Bank, is responsible for the supervision of the implementation of 
AML policy, which includes implementation of Know Your Customer 
(KYC) principles in the banking industry.  Bank Indonesia's 
objective in this matter is to ensure that banks are not being 
utilized as targets and or mediums for money laundering activities 
since banks are the financial institutions most used by money 
launderers.  In addition, Bank Indonesia is also authorized to 
supervise Non-Bank Money Changers given the fact that Money Changers 
are the next likely group to be used for money laundering, and Money 
Remittance business.  This is also in line with the MoonexQu dering 
Law and international standards, which states th`t o*ey Changers 
shall also be subject to KYC principlesand AML. 
 
¶11. BI issued Regulation No. 3/10/PBI/001, "The Application of Know 
Your Customer Priniples," on June 18, 2001.  This regulation 
requies banks to obtain information on prospective custmers, 
including third party beneficial owners, an to verify the identity 
of all owners, with persnal interviews if necessary.  The 
regulation als requires banks to establish special monitoring unts 
and appoint compliance officers responsible fr implementation of 
the new rules and to maintainadequate information systems to comply 
with the aw.  Finally, the regulation requires banks to anayze and 
monitor customer transactions and reportto BI within seven days any 
"suspicious transactons" in excess of Rp 100 million (approximately 
$1,000).  The regulation defines suspicious transacions according 
to a 39-point matrix that include key indicators such as unnusual 
cash transaction, unusual ownership patterns, or unexplained 
chages in transactional behavior. BI specifically requres banks to 
treat as suspicious any transaction to or from countries "connected 
with the producion, processing and/or marrket for drugs or 
terroism." 
 
¶12. BI has issued an Internal Circular Leter No. 6/50/INTERN, dated 
September 10, 2004 concerning Guidelines for the Supervision and 
Examination of the Implementation of KYC and AML by Commercial 
Banks.  In addition, BI also issued a Circular Letter to Commercial 
Banks No. 6/37/DPNP dated September 10, 2004 concerning the 
Assessment and Imposition of Sanction on the Implementation of KYC 
and other Obligation Related to Law on Money Laundering Crime. BI is 
also preparing Guidelines for Money Changers on Record Keeping and 
Reporting Procedures and Money Changer Examinations given by BI 
examiners. 
 
Cross Border Cash Carrying 
-------------------------- 
¶13.  Other mandatory reports in Indonesia AML regime, such as Cross 
Border Cash Carrying reports, have also been increasing 
significantly.  Currently, banks must report all foreign exchange 
transactions and foreign obligations to BI.  With respect to the 
physical movement of currency, Article 16 of Law No. 15/2002 
contains a reporting requirement for any person taking cash into or 
out of Indonesia in the amount of 100 million Rupiah (approximately 
$11,000) or more, or the equivalent in another currency, which must 
be reported to the Director General of Customs and Excise (DGCE). 
These reports must be given to the PPATK in no-later-than five 
 
JAKARTA 00003140  004 OF 007 
 
 
business days and contain details of the identity of the person. 
 
¶14. Indonesian Central Bank regulation 3/18/PBI/2001 and the DGCE 
Decree No.01/BC/2005 concerning the Reporting Procedure of Cross 
Border Cash Carrying, launched on January 2005, contain the 
requirements and procedures of inspection, prohibition, deposit of 
Indonesia Rupiah into or out of Indonesia.  The Decree provides 
implementing guidance for Ministry of Finance Regulation 
No.624/PMK.04/2004 of December 31, 2004, which requires individuals 
who import or export more than rupiah 50 to 100 million in cash 
(approximately $5,500-$11,000) to report such transactions to 
Customs. This information is to be declared on the Indonesian 
Customs Declaration, 524 Forms BC 3.2 have been filed with Customs 
and submitted to PPATK by the end of 31 December 2005 and 1,432 
Forms by the end of 31 December 2006. 
 
¶15. As of 30 June 2007, 1,855 Forms BC 3.2 have been filed with 
Customs and submitted to PPATK. The reports were derived from 2 
(two) airports, namely Jakarta Cengkareng and Denpasar, 2 (two) 
seaports, namely Batam and Tanjung Balai Karimun, and 1 (one) post 
office in Bandung.  Up to 31 July 2007 PPATK obtained 1,887 reports 
from DGCE, derived from five jurisdictions of Customs: Jakarta, 
Tanjung Balai Karimun, Bandung, Batam and Denpasar.  And up to 31 
July 2007, Indonesian National Police has conducted investigation of 
20 cases derived from reporting of Cross-Border Cash Carrying 
Report. 
 
Bank Information, Disclosure and Records 
---------------------------------------- 
 
¶16. There is a mechanism to obtain access to confidential 
information from bank through BI Regulation Number 2/19/PBI/2000 on 
September 7, 2000 concerning "Requirements and Procedure for Written 
Order or Permission to Access Confidential Bank Information."  PPATK 
has the authority to conduct supervision and monitoring compliance 
of providers of financial services.  PPATK may also advise and 
assist relevant authorities concerning information obtained by the 
PPATK in accordance with the provisions of this Law No 15/2002. 
Thus, there are mechanisms governing information exchange between 
the Directorate General for Taxation (DG Tax) and PPATK by 
considering limitations stipulated under Laws and regulations 
related with these two agencies and the MOU between them.  The Law 
also stipulates some provisions in which PPATK shall have authority 
to request  suspicious transactions reports and additional 
information from providers of financial services. 
 
¶17. Banks and non-bank financial institutions (NBFI) shall keep and 
maintain documents and records related to its customers for at least 
five years after the closing of a customer's account.  Indonesia's 
bank secrecy law covers information on bank depositors and their 
accounts. Such information is generally kept confidential and can 
only be accessed by the authorities in limited circumstances. 
However, Article 27(4) of the Law No. 15/2002 now expressly exempts 
the PPATK from "the provisions of other laws related to bank secrecy 
and the secrecy of other financial transactions" in relation to its 
functions in receiving and requesting reports and conducting audits 
of providers of financial services.  In addition, Article 14 of the 
Law No. 15/2002 exempts providers of financial services from bank 
secrecy provisions when carrying out their reporting obligations, 
and Article 15 of their anti-money laundering legislation gives 
providers of financial services, their officials and employees 
protection from civil or criminal action in making such disclosures. 
 
 
Freezing, Blocking and Seizing Assets 
------------------------------------- 
 
¶18. Indonesian laws provide only limited authority to block or seize 
assets.  Under BI regulations 2/19/PBI/2000, police, prosecutors, or 
judges may order the seizure of assets of individuals or entities 
that have been either declared suspects, or indicted for a crime. 
This does not require the permission of BI, but, in practice, for 
law enforcement agencies to identify such assets held in Indonesian 
banks, BI's permission would be required. In the case of money 
laundering as the suspected crime, however, bank secrecy laws would 
not apply, according to the anti-money laundering law. 
 
 
JAKARTA 00003140  005 OF 007 
 
 
¶19. The GOI has limited formal instruments to trace and forfeit 
criminal and civil assets.  Under the Indonesian legal system, all 
types of confiscations against all types of assets must be taken 
through criminal justice proceedings and be based on a court order. 
This confiscation process is initiated with freezing and seizing 
process against said assets.  Thus, the GOI has the authority to 
trace and freeze assets of individuals or entities on the UNSCR 1267 
Sanctions Committee's consolidated list, and through BI, has 
circulated the consolidated list to all banks operating in 
Indonesia, with instructions to freeze any such accounts. 
 
¶20. When new names are added to the 1267 list, however, the GOI's 
multi-step process through three agencies is currently too complex 
and inefficient to send out asset-freezing instructions in a timely 
manner.  The interagency process to issue freeze orders, which 
includes the Foreign Ministry, Attorney General, Police, and BI, 
takes several weeks or more from UN designation to bank 
notification.  Banks also note that without very specific 
information, the preponderance of similar names and inexact 
addresses, along with the lack of a unique identifier (such as the 
U.S. social security number) in Indonesia make identifying correct 
accounts very difficult.  The implementation of this process has not 
led to the discovery of accounts or assets of individuals or 
entities on UN 1267 consolidated list.  However, during the course 
of terrorism investigations, the Indonesia police have located and 
frozen accounts of individuals on the UN 1267 consolidated list. 
 
¶21. Article 32 of Law Number 15 Year 2002 as amended by Law Number 
25 Year 2003 provides that investigators, public prosecutors and 
judges are authorized to freeze any assets which are reasonably 
suspected to be the proceeds of crime. Article 34 stipulates that if 
sufficient evidence is obtained during the examination of the 
defendant in court, the judge may order the sequestration of assets 
known or reasonably suspected to be the proceeds of crime which have 
not already been sequestered by the investigator or public 
prosecutor concerned.  In addition, Article 37 provides for a 
confiscation mechanism if the defendant dies prior to the rendition 
of judgment.  Goods forfeited shall be defined as goods owned by the 
accused derived from an offence and goods intentionally used to 
commit an offence. 
 
¶22. In October 2006, the GOI submitted to Parliament additional 
amendments to Law No. 15/2002 that would provide the PPATK with 
preliminary investigative authority and the ability to temporarily 
freeze assets.  The amendments are intended to provide technical 
investigative support to police and prosecutors and to deter capital 
flight.  The GOI in August 2006 enacted Indonesia's first Witness 
and Victim Protection Law (No. 13/2006).  Indonesia's AML Law and 
Government Implementing Regulation No. 57/2003 also provide 
protections to whistleblowers and witnesses. 
 
¶23. The October 18, 2002, emergency counter-terrorism regulation, 
the Government Regulation in Lieu of Law of the Republic of 
Indonesia (Perpu), No. 1 of 2002 on Eradication of Terrorism 
criminalizes terrorism and provides the legal basis for the GOI to 
act against terrorists, including the tracking and freezing of 
assets.  The Perpu provides a minimum of three years and a maximum 
of 15 years imprisonment for anyone who is convicted of 
intentionally providing or collecting funds that are knowingly used 
in part or in whole for acts of terrorism.  This regulation is 
necessary because Indonesia's anti-money laundering law criminalizes 
the laundering of "proceeds" of crimes, but it is often unclear to 
what extent terrorism generates proceeds. 
 
¶24. The Special Detachment 88 of the Indonesian National Police and 
the Task Force of Terrorism and Transnational Organized Crime of the 
AGO maintain the statistic related to financing of terrorism.  The 
Indonesian police have ordered the freezing of accounts owned by 
individuals suspected of connection with acts of terrorism.  These 
individuals include Ali Gufron, Parlindungan Siregar, Utomo 
Pamungkas, Abdul Azis, Nasaruddin Bin Abdul Jalil, Faithi Bin Abu 
Bakar Bafana, Siliwangi, Ramiah Nasution, Susmiati, Tursiak, 
Syarifah Zarniyah, Sujiati, Edi Indra, Fahjry, Hernianto, Muthmainah 
and Hussein. Also accounts belonging to a company PT Yasa Edukatama. 
 
 
¶25. National Police investigators have investigated some 
 
JAKARTA 00003140  006 OF 007 
 
 
perpetrators of the crime of terrorism, in which some of them are 
involved in Bali Bombing Attacks I and II, terrorist attack in J. W 
Marriott Hotel, terrorist attack in the residence of Philippines 
Ambassador, terrorist attack in Australian Embassy. National Police 
investigators investigated such perpetrators and convicted them for 
the crime of terrorism, not terrorist financing with a consideration 
that the criminal sanction of terrorism crime is more serious than 
terrorist financing.  If investigators require information on the 
flow of fund related with terrorist attacks, National Police 
investigators always coordinate with PPATK.  In October 2004, an 
Indonesian court convicted and sentenced one Indonesian to four 
years in prison on terrorism charges connected to his role in the 
financing of the August 2003 bombing of the Jakarta Marriott Hotel. 
 
Alternative Remittance Systems 
------------------------------ 
 
¶26.  The GOI has recently begun to take into account alternative 
remittance systems or charitable or nonprofit entities in its 
strategy to combat terrorist finance and money laundering.  The 
PPATK has issued guidelines for non-bank financial service providers 
and money remittance agents on the prevention and eradication of 
money laundering and the identification and reporting of suspicious 
and other cash transactions.  The GOI has initiated a dialogue with 
charities and nonprofit entities on improving regulation and 
oversight of those sectors. 
 
International Agreements and Arrangements 
----------------------------------------- 
 
¶27. Indonesia is an active member of the Asia/Pacific Group on Money 
Laundering (APG) and the Bank for International Settlements. BI 
claims that it voluntarily follows the Basel Committee's "Core 
Principles for Effective Banking Supervision."  The GOI has enacted 
Law Number 7 Year 1997 to implement the 1988 Vienna Convention 
against the Illicit Traffic in Narcotic Drugs and Psychotropic 
Substances. In addition the GOI also has enacted Law Number 22 Year 
1997 concerning Drugs and Psychotropic Substances, which makes the 
possession, purchase or cultivation of narcotic drugs or 
psychotropic substances for personal consumption a criminal offence. 
 
 
¶28.  The GOI has signed, but not yet ratified, the UN Convention 
against Transnational Organized Crime. In 2006 Indonesia formally 
ratified two International Conventions regarding terrorism: The 
International Convention for the Suppression of Terrorist Bombing, 
1997, was ratified by Law Number 5 Year 2006 and The International 
Convention for the Suppression of the Financing Terrorism, 1999, was 
ratified by Law Number 6 Year 2006.   Cooperation between the 
Indonesian law enforcement agencies and its foreign counterparts is 
intended to prevent and combat the crime of money laundering, which 
is a trans-national crime. 
 
¶29. Bilateral arrangements on mutual legal assistance on criminal 
matters will facilitate the seizure of such assets as governed in 
Law Number 1 Year 2006 concerning Mutual Legal Assistance in 
Criminal Matters. Currently, Indonesia has concluded bilateral 
treaties with Australia, the People's Republic of China and Republic 
of Korea.  Investigators, public prosecutors or judges have the 
authority to order banks or financial service providers to freeze 
the assets of any person believed or with reason to believe to be 
the proceeds from acts of terrorism and/or crimes related to 
terrorism, irrespective of the amount or value. 
 
¶30.  In June 2004, PPATK became a member of the Egmont Group and has 
entered into MoUs with 22 (twenty two) FIUs.   As such, it is bound 
to share financial intelligence with other members in accordance 
with the organization's charter.  The PPATK is actively pursuing 
broader cooperation with other Financial Intelligence Units (FIUS) 
and has MOUs with Thailand, Malaysia, Republic of Korea, 
Philippines, Romania, Australia, Belgium, Italy, Spain, Poland, 
Peru, Mexico, China, Burma, Canada, South Africa and the Cayman 
Islands.  The PPATK has also entered into an Exchange of Letters 
enabling international exchange with Hong Kong.  Indonesia has 
signed Mutual Legal Assistance Treaties with Australia, China and 
South Korea, and Indonesia joined other ASEAN nations in signing the 
ASEAN Treaty on Mutual Legal Assistant in Criminal Matter on 
 
JAKARTA 00003140  007 OF 007 
 
 
November 29, 2004.  The Indonesian Regional Law Enforcement 
Cooperation Centre was formally opened in 2005 and was created to 
develop the operational law enforcement capacity needed to fight 
transnational crimes. 
 
¶31. Regarding international mechanisms, Article 43 of Government 
Regulation in Lieu of Law (Perpu) Number 1 Year 2002 concerning the 
Eradication of Criminal Acts of Terrorism as Enacted to be the Law 
Number 15 Year 2003 provides international cooperation with other 
countries in the field of intelligence, police, and other technical 
cooperation to combat terrorism and financing of terrorist in 
according to prevailing relevant laws.  In this regard, the foreign 
authority shall address the request in writing to the Indonesian 
investigator, which, after been reviewed, the investigator will 
order the bank or the financial service provider wherein the suspect 
has the asset, to freeze it.  The bank or the financial service 
provider shall then immediately freeze the asset. 
 
¶32.  In addition, there is other system applied, which is exchange 
information and intelligence between countries that is crucial for 
the effective combating the financing of terrorist and terrorism, in 
which such exchange has been promoted inter-alia within the context 
of International Criminal Police Organization (ICPO) - INTERPOL. The 
investigators shall conduct a freezing if it relates with assets 
located in other jurisdiction and then asking for assistances from 
Interpol and there has been existing mechanism thru INTERPOL for 
Indonesia. 
 
Continuing Challenges 
--------------------- 
 
¶33. Sustained public awareness campaigns, new bank and financial 
institution disclosure requirements, and the PPATK's support for 
Indonesia's first credible anticorruption drive have led to 
increased public awareness about money-laundering and, to a lesser 
degree, terrorism finance.  Weak human and technical capacity, poor 
interagency cooperation, and corruption, however, still remain 
significant impediments to the continuing development of an 
effective and credible AML regime. 
 
¶34. The highest levels of GOI leadership should continue to 
demonstrate strong support for strengthening Indonesia's anti-money 
laundering regime.  In particular, the GOI must continue to improve 
capacity and interagency cooperation in analyzing suspicious and 
cash transactions, investigating and prosecuting cases, and 
achieving deterrent levels of convictions and custodial and 
administrative sentences and penalties.  As part of this effort, 
Indonesia should review the adequacy of its Code for Criminal 
Procedure and Rules of Evidence and enact legislation to allow the 
use of modern techniques to enter evidence in court proceedings. 
Indonesia should review and streamline its process for reviewing UN 
designations and identifying, freezing and seizing terrorist assets, 
and become a party to the UN Convention against Transnational 
Organized Crime. 
 
HUME