Logo Home    |    About us    |    Practice areas    |    Lawyers    |    News    |    Join us    |    FAQ
Tiendas Law Offices | Legal updates
Do you want to receive our publication regularly? Subscribe here

Do you have a testimonial about us?
Write here or view here


Legal Updates

Money Laundering and Terrorism Funding - Bank Indonesia Circular

Bank Indonesia (BI) has issued a Circular, No. 11/31/DPNP with the express intent of providing a set of guidelines to facilitate the implementation of the anti-money laundering and prevention of terrorism funding program contained in BI Regulation No. 11/28/PBI/2009 issued on 1 July 2009.

These guidelines contain minimum standards that must be fulfilled by Indonesian banks to preparing guidelines on anti-money laundering programs and the prevention of terrorism financing to commercial banks. The standard guidelines include an attachment to the circular which cover 13 basic subject areas:
  1. Management

  2. Policy – Customer and Enhanced Due Diligence

  3. Risk Based Approach

  4. Receipt, Identification, and Verification

  5. Politically Exposed Persons

  6. Implementation Procedures

  7. Cross Border Correspondent Banking

  8. Fund Transfer Procedures

  9. Internal Controls

  10. Information Management Systems

  11. Human Resources and Employee Training

  12. Policies and Procedures for Implementation of Anti-Money Laundering and Prevention of Terrorism Funding Measures

  13. Document and Report Management

The guidelines go  into some detail defining and explaining the manner in which certain transactions might be carried out in order to avoid detection. The guidelines explain the concepts of smurfing and cuckoo smurfing, among others. Smurfing is the avoidance of reporting requirements by breaking related transactions up into multiple amounts and under multiple names. In contrast, cuckoo smurfing involves the transfer of the proceeds of crime through a third party account where that third party is not aware that their account is being used to deal with the proceeds of crime.

The circular is effective as of 30 November 2009.

Comment for this publication

[post comment] [view all comment] [view publication index]

No comment for this publication

Site Map:
Home |  About us |  Practice areas |  Lawyers |  News |  Legal updates |  Join us |  FAQ
22nd floor, Menara Imperium
Jl. HR. Rasuna Said Kav.#1 Jakarta 12980
Phone: (6221) 835 1069; (6221) 835 1082 Fax: (6221) 835 1076
e-mail: general@tiendaslaw.com
Copyright © 2014 Tiendas Law Offices