--- title: "Indonesia (ID) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/indonesia/ source_html: /jurisdictions/indonesia/index.html description: "Financial integrity intelligence for Indonesia (ID): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T17:53:23Z content_sha256: 337170da1eb125ec107a77e531de0c1ab31f344a0c0129cc1ad1be91c1308ef8 generator: "fe-fleet/md-twin@1.0" --- # Indonesia (ID) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Indonesia ID Domains covered 8 of 8 Sources 140 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Decreasing Enablement vs enforcement: Mixed Indonesia is a full FATF member (since Oct 2023), governed by AML Law No.8/2010, with PPATK as FIU and OJK/Bank Indonesia/CoFTRA as sectoral supervisors. More Crypto oversight transferred from Bappebti/CoFTRA to OJK in Jan 2025 under the P2SK financial-sector law. Follow-up reports (May 2025, June 2026) show steady technical-compliance upgrades, though effectiveness gaps persist in asset recovery, DNFBP supervision, and beneficial-ownership verification. Key deficiencies - Beneficial ownership registry compliance below 30% of registered corporations, with no independent verification of submitted data - DNFBP sectors (notaries, lawyers, real estate agents) not effectively implementing AML/CFT preventive measures - Low volume of money-laundering investigations/prosecutions for high-proceeds predicate crimes, especially forestry/environmental crime - Asset recovery and confiscation of criminal proceeds, particularly assets held abroad, remains weak - Sanctions for non-compliance in financial and DNFBP sectors are frequently limited to warnings rather than dissuasive penalties Recent developments (18m) - FATF adopted Indonesia's Follow-Up Report in May 2025, re-rating Recommendation 7 (proliferation-financing TFS) from Partially Compliant to Largely Compliant - FATF adopted a further Follow-Up Report in June 2026 re-rating Recommendation 6 (terrorism-financing TFS) from Partially Compliant to Compliant; Indonesia now exits regular 4th-round follow-up reporting to Plenary - PPATK Decree 670 of 2025 (enacted 12 December 2025) tightened the 'reasonable basis' evidentiary standard for DTTOT terrorist-list nominations - Crypto regulatory authority formally transferred from Bappebti/CoFTRA to OJK in January 2025, with a mandatory regulatory sandbox for new licensees - PPATK-supported convictions (2024-2025) of individuals financing Syria-based terrorist networks via cryptocurrency, using on-chain evidence at trial - Major corruption/tin-mining (Timah) asset-recovery action: seized smelters worth an estimated $362-422 million handed to state miner PT Timah (October 2025) - OCCRP-reported takedown of a shell-company/QRIS/crypto money-laundering network tied to illegal online gambling, with ~$32 million in assets seized Brief ## Lead signal #### Lead Signal Indonesia's financial-crime enforcement architecture moved visibly this cycle as a coordinated push by the Financial Services Authority (OJK), Bank Indonesia, the financial intelligence unit PPATK and the national police intensified efforts to sever payment pathways supporting illegal online gambling. Officials said at a press conference in early November 2026 that banks have been instructed to apply enhanced due diligence checks and block accounts linked to the gambling networks, with 39,923 accounts now blocked, an increase of 1,127 since early October 2026. The total financial turnover estimated to have coursed through these networks was put at roughly Rp86.8 trillion. The claim traces to statements from named officials relayed across multiple independent outlets rather than to a primary OJK or PPATK instrument reached directly this cycle, a sourcing gap that keeps confidence at the probable rather than confirmed tier. Read full brief #### Lead Signal Indonesia's financial-crime enforcement architecture moved visibly this cycle as a coordinated push by the Financial Services Authority (OJK), Bank Indonesia, the financial intelligence unit PPATK and the national police intensified efforts to sever payment pathways supporting illegal online gambling. Officials said at a press conference in early November 2026 that banks have been instructed to apply enhanced due diligence checks and block accounts linked to the gambling networks, with 39,923 accounts now blocked, an increase of 1,127 since early October 2026. The total financial turnover estimated to have coursed through these networks was put at roughly Rp86.8 trillion. The claim traces to statements from named officials relayed across multiple independent outlets rather than to a primary OJK or PPATK instrument reached directly this cycle, a sourcing gap that keeps confidence at the probable rather than confirmed tier. Read architecturally rather than as an isolated enforcement incident, the development is notable for what it signals about the payment rails themselves. The persistence and scale of gambling-linked deposit flows through domestic retail payment infrastructure, continuing even as blocking volumes rise, suggests a structural vulnerability in account-opening and transaction-monitoring controls at the institution level, not merely a pattern of individual bad actors. The multi-agency character of the response, spanning the prudential regulator, the central bank, the financial intelligence unit and law enforcement, points to an escalating coordinated posture rather than a single-agency campaign. #### Other Developments Standing AML/CTF profile reaffirmed. Indonesia remains a full member of the Financial Action Task Force, admitted as the fortieth member in October 2023, and is not named on any FATF increased-monitoring list. A third enhanced follow-up report dated June 2026 rated the country compliant or largely compliant on the great majority of the forty FATF Recommendations, with seven rated fully compliant, thirty largely compliant and three partially compliant. The report credited a December 2025 PPATK decree with securing an upgrade on Recommendation 6, concerning targeted financial sanctions related to terrorism and terrorist financing. This assessment rests on a secondary compliance whitepaper rather than FATF's own follow-up document, which was not directly retrieved this cycle, so the rating breakdown is carried at the same probable confidence as the enforcement signal above. #### Cross-Monitor Connections The gambling-payment crackdown sits at the intersection of financial-integrity and payments-infrastructure concerns: the mechanism by which illicit turnover reaches the banking system is the same retail payment rail infrastructure that is the subject of separate operational-resilience and data-governance reform activity in Indonesia this period. A regulator-level data-governance initiative aimed at strengthening transaction integrity and fraud prevention across payment service providers is a natural complement to the account-blocking campaign, since stronger payment-system data-sharing arrangements between Bank Indonesia and payment service providers would be expected to improve the traceability of exactly the kind of flows implicated in the gambling enforcement push. Where conflict-finance or state-capture-adjacent findings touch on gambling or illicit gaming-finance ecosystems elsewhere in the region, this Indonesian enforcement posture is a relevant comparator for the enablement-versus-enforcement framing used across the broader monitoring effort. #### Outlook The near-term marker to watch is whether account-freeze volumes continue to climb through the remainder of November 2026 and whether a primary OJK or PPATK instrument becomes available to firm up the probable-confidence figures cited this cycle. The FATF compliance position is unlikely to change materially before the next scheduled follow-up assessment, but continued domestic enforcement intensity against gambling-linked flows is the more immediate signal for financial institutions operating retail payment accounts in Indonesia. As with all forward framing here, this is analytical orientation, not a prediction of regulatory outcomes. Earlier periodic briefs (5) 8 Nov 2026 · fim-2026-11-08 #### Lead Signal Indonesia's financial-crime enforcement architecture moved visibly this cycle as a coordinated push by the Financial Services Authority (OJK), Bank Indonesia, the financial intelligence unit PPATK and the national police intensified efforts to sever payment pathways supporting illegal online gambling. Officials said at a press conference in early November 2026 that banks have been instructed to apply enhanced due diligence checks and block accounts linked to the gambling networks, with 39,923 accounts now blocked, an increase of 1,127 since early October 2026. The total financial turnover estimated to have coursed through these networks was put at roughly Rp86.8 trillion. The claim traces to statements from named officials relayed across multiple independent outlets rather than to a primary OJK or PPATK instrument reached directly, a sourcing gap that keeps confidence at the probable rather than confirmed tier. Read architecturally rather than as an isolated enforcement incident, the development is notable for what it signals about the payment rails themselves. The persistence and scale of gambling-linked deposit flows through domestic retail payment infrastructure, continuing even as blocking volumes rise, suggests a structural vulnerability in account-opening and transaction-monitoring controls at the institution level, not merely a pattern of individual bad actors. The multi-agency character of the response, spanning the prudential regulator, the central bank, the financial intelligence unit and law enforcement, points to an escalating coordinated posture rather than a single-agency campaign. #### Other Developments Standing AML/CTF profile reaffirmed. Indonesia remains a full member of the Financial Action Task Force, admitted as the fortieth member in October 2023, and is not named on any FATF increased-monitoring list. A third enhanced follow-up report dated June 2026 rated the country compliant or largely compliant on the great majority of the forty FATF Recommendations, with seven rated fully compliant, thirty largely compliant and three partially compliant. The report credited a December 2025 PPATK decree with securing an upgrade on Recommendation 6, concerning targeted financial sanctions related to terrorism and terrorist financing. This assessment rests on a secondary compliance whitepaper rather than FATF's own follow-up document, which was not directly retrieved, so the rating breakdown is carried at the same probable confidence as the enforcement signal above. #### Cross-Monitor Connections The gambling-payment crackdown sits at the intersection of financial-integrity and payments-infrastructure concerns: the mechanism by which illicit turnover reaches the banking system is the same retail payment rail infrastructure that is the subject of separate operational-resilience and data-governance reform activity in Indonesia this period. A regulator-level data-governance initiative aimed at strengthening transaction integrity and fraud prevention across payment service providers is a natural complement to the account-blocking campaign, since stronger payment-system data-sharing arrangements between Bank Indonesia and payment service providers would be expected to improve the traceability of exactly the kind of flows implicated in the gambling enforcement push. Where conflict-finance or state-capture-adjacent findings touch on gambling or illicit gaming-finance ecosystems elsewhere in the region, this Indonesian enforcement posture is a relevant comparator for the enablement-versus-enforcement framing used across the broader monitoring effort. #### Outlook The near-term marker to watch is whether account-freeze volumes continue to climb through the remainder of November 2026 and whether a primary OJK or PPATK instrument becomes available to firm up the probable-confidence figures cited. The FATF compliance position is unlikely to change materially before the next scheduled follow-up assessment, but continued domestic enforcement intensity against gambling-linked flows is the more immediate signal for financial institutions operating retail payment accounts in Indonesia. As with all forward framing here, this is analytical orientation, not a prediction of regulatory outcomes. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Indonesia's financial-integrity picture turns on a single structural development: the transfer of crypto-asset regulatory supervision from the commodity-futures regulator Bappebti to the Financial Services Authority, OJK, treating crypto-asset businesses as financial institutions. This is now structurally complete in primary law, embedded through Law No. 4 of 2026's amendment to the 2023 P2SK (financial sector development and strengthening) framework, which extends consumer-protection rules to crypto-asset businesses. The shift is architecturally significant rather than incident-driven: it relocates an entire asset class from a commodities-style oversight model into the perimeter of a financial-institution supervisor, with the obvious downstream implication that AML/CTF expectations designed for banks and other financial institutions now have a textual hook to reach crypto-asset operators. What is not yet visible is the implementing detail. No newly dated AML-specific circular giving operational effect to the transfer, in the sense of concrete customer due diligence, reporting, or licensing thresholds for crypto firms under OJK's remit, was located within the current window. The structural move has happened in law; the supervisory mechanics that will determine how meaningfully it bites remain to be issued or to be found. #### Other Developments The FATF Recommendation 6 upgrade remains standing. Indonesia's third Enhanced Follow-Up Report credits PPATK Decree 670 of 12 December 2025 with closing a previously identified deficiency, moving Recommendation 6 (targeted financial sanctions related to terrorism and terrorist financing) to Compliant. The decree tightens the domestic terrorism-designation listing standard and establishes a 24-hour operational window for targeted financial sanctions action without prior notice. This is a rating change rather than a new event, but it continues to anchor Indonesia's position as a FATF member, outside the grey list, with its sanctions-implementation architecture rated favourably against the standard most directly tied to terrorist-financing designations. The bank-account disruption campaign against online-gambling proceeds continues. OJK, working with the communications and digital ministry Komdigi, has ordered banks to apply enhanced due diligence or blocking to accounts linked to online gambling, with reporting putting the number of affected accounts at approximately 38,796 as of early October 2026. This sits on the enforcement side of the architecture-versus-incident distinction: it is an operational, infrastructure-level disruption action against proceeds of a predicate offence rather than a new designation or sanctions measure, and it has not altered Indonesia's headline AML/CTF rating. No primary OJK or PPATK notice was located to confirm the figure directly, so the finding is treated as probable rather than confirmed pending a first-party source. #### Cross-Monitor Connections The crypto-asset supervisory transfer to OJK is the most consequential cross-monitor hook: a change that is read here as a financial-integrity perimeter question (who now has the supervisory and AML mandate over crypto-asset firms) is simultaneously a market-structure and product-innovation question for payments-sector analysis, since bringing crypto-asset businesses under a financial-institution supervisor changes the compliance posture firms serving Indonesian customers must build toward. The bank-account disruption campaign against online-gambling proceeds likewise has a payments-sector dimension, since blocking or subjecting tens of thousands of accounts to enhanced due diligence is an operational event for the banks executing it, independent of its predicate-offence classification. Neither connection is elaborated further here; each is a routing note to the adjacent reading, not a conclusion about it. #### Outlook The near-term question for Indonesia's financial-integrity position is whether the crypto-asset supervisory transfer to OJK is followed by implementing AML-specific rules, such as customer due diligence standards, reporting obligations, or licensing conditions tailored to crypto-asset operators, or whether the primary-law change sits for a period without operational detail. Absent such implementation, the structural reform remains consequential as an architecture statement but limited in its immediate supervisory bite. The FATF Recommendation 6 upgrade is unlikely to move further in the near term absent a new mutual evaluation cycle, and the online-gambling account-disruption campaign is likely to continue as an ongoing operational posture rather than resolve to a single endpoint. As scheduled, Indonesia's next substantive FATF-facing milestone would be governed by its mutual evaluation cycle rather than by any near-dated event visible in the current material. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Indonesia's financial-integrity picture this cycle is defined by a positive technical-compliance signal from FATF set against an expanding, extraterritorially reaching enforcement architecture for crypto-asset activity. FATF's June 2026 3rd Enhanced Follow-up Report upgraded Indonesia's technical-compliance rating on targeted-financial-sanctions criteria, crediting PPATK Decree 670 of 12 December 2025 for closing a deficiency identified in Indonesia's 2023 Mutual Evaluation Report. This is a confirmed, primary-sourced development: the FATF document itself was retrieved and reviewed directly. Running in parallel, Indonesia's 2026 Financial Services Omnibus Law has handed the Otoritas Jasa Keuangan a freeze and block power over non-compliant crypto activity that extends to foreign operators with no local presence in Indonesia, alongside criminalising unlicensed crypto-asset business outright. The two developments together describe a jurisdiction simultaneously improving its standing against the international sanctions-implementation standard and sharply escalating its domestic enforcement reach over digital-asset flows, including those originating offshore. #### Other Developments Civil-society AML dispute. The Danantara Monitor coalition alleges that Article 50A of the P2SK Law, introduced via so-called Patriot Bonds provisions, weakens anti-money-laundering due diligence; PPATK disputes this characterisation directly, producing a genuinely contested reading of the same statutory provision that has not resolved by the close of this cycle's research window. Gambling-linked account screening. OJK ordered banks to use National Identity Numbers to trace accounts connected to online gambling, with Enhanced Due Diligence or blocking applied to 38,796 accounts; PPATK separately suspended transactions on 5,762 accounts belonging to online gambling operators. This finding rests on corroboration from two independent secondary outlets rather than a retrieved primary OJK circular, holding confidence at Probable. Standing AML/CTF architecture unchanged. Indonesia continues to operate its AML/CTF regime under Law No. 8 of 2010, Government Regulation 74/2015, and POJK No. 8 of 2023, with Bank Indonesia, OJK and PPATK as joint supervisors; Indonesia has been a FATF member since October 2023 and is not grey-listed. #### Cross-Monitor Connections The OJK's new extraterritorial freeze and block power over foreign crypto operators is directly relevant to the crypto monitor's licensing and cross-border-transfer tracking, where the absence of any licence-passporting regime previously left a practical gap this power now closes. The same NIK-based bank-screening order against gambling-linked accounts is a shared finding with world-payments' AML/CFT and financial-crime tracking, sourced there via the Sentinel feed; this brief retains the underlying financial-integrity analysis while world-payments carries the payments-infrastructure framing of the same development. #### Outlook The unresolved dispute between the Danantara Monitor coalition and PPATK over Article 50A's effect on AML due diligence is worth tracking for whether it prompts a formal FATF or APG review request, since the coalition's underlying ask was reportedly for exactly that external scrutiny. On the crypto-enforcement side, how OJK operationalises its new extraterritorial freeze and block power in practice, particularly the mechanics of reaching a foreign operator with no local presence, will determine whether the power functions as a credible deterrent or remains principally a legislative statement of intent. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Indonesia's financial intelligence unit, PPATK, has published data showing that QRIS, the national quick-response payment standard, has become the dominant deposit rail for online gambling, with QRIS-based deposits reaching IDR 12.36 trillion, 56.04 percent of total online-gambling deposit value across 198.77 million transactions, in the first half of 2026. The same disclosure reports 2,815 accounts holding IDR 325.43 billion suspended in connection with World-Cup-period gambling activity. Rather than seeking to restrict QRIS as infrastructure, PPATK's public framing presses payment-service providers toward stronger merchant verification at onboarding, a regulatory choice that shifts compliance burden onto the private payment sector instead of constraining a payment rail that is, by PPATK's own characterisation, of substantial benefit to the broader economy. #### Other Developments Content-blocking continues in parallel. Indonesia's Ministry of Communication and Digital Affairs (Komdigi) has restated a cumulative content-blocking total of 4.1 million gambling-content items removed between 20 October 2024 and 28 September 2026, reported by the national news agency ANTARA, with a stated ministerial framing oriented toward curbing transnational gambling networks. This finding rests on T2 news-agency reporting of a ministerial statement, without independent primary-instrument confirmation obtained this cycle. The FATF standing-compliance record is unchanged. A 3rd Enhanced Follow-up Report and Technical Compliance Re-Rating for Indonesia was published by FATF in June 2026, predating the current cycle's window; Indonesia is not on the FATF increased-monitoring list, and no new plenary action has been recorded this cycle. Crypto-asset AML supervision continues to consolidate under OJK. Indonesia's Financial Services Authority, OJK, holds crypto-asset AML/CFT supervisory authority under the amended P2SK Law, effective 17 June 2026; this is carried forward as standing architecture, with no new Indonesia-specific crypto-AML enforcement action identified within this cycle's window. #### Cross-Monitor Connections The QRIS deposit-concentration finding connects directly to the World Payments Monitor's coverage of Bank Indonesia Regulation No. 10 of 2025, which restructures payment-service-provider licensing and, separately, prohibits payment-system providers from accepting or processing virtual currency as a source of payment funds; the gambling-deposit exploitation PPATK describes sits on the licensed, non-crypto side of that same payment-rail architecture. It also connects to the gambling-focused monitor's coverage of Komdigi's blocking programme: the two agencies are pursuing parallel but distinct theories, content suppression versus payment-rail accountability, against the same underlying online-gambling activity. #### Outlook Absent a major escalatory event, PPATK's preference for compliance-burden-shifting onto payment-service providers, rather than restricting QRIS at the infrastructure level, is likely to persist. The practical question going forward is whether merchant-verification tightening by payment-service providers measurably reduces the deposit share flowing through QRIS into gambling activity, or whether enforcement remains concentrated on reactive account suspension after the fact. Indonesia's FATF status is expected to remain stable barring a new plenary determination. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Indonesia has formalised a cross-agency financial-disruption strategy against illegal online gambling, anchored in Law No. 4 of 2026, the P2SK Amendment. A task force linking Komdigi, the Financial Services Authority (OJK) and Bank Indonesia now targets mule bank accounts that fund illegal gambling operations, on the premise that site-blocking alone had proven insufficient. Approximately 38,000 accounts have been referred to OJK, with 32,500 closed. Indonesia's financial intelligence unit, PPATK, separately reported IDR286.84 trillion, approximately 17.3 billion US dollars, in online-gambling-linked transactions in 2025 alone, across more than 422 million transactions involving approximately 12.3 million people, a figure that gives shape to the scale of the laundering problem the task force is designed to address. #### Other Developments National Police enforcement statistics disclosed alongside the financial-disruption campaign. 718 illegal online-gambling cases were handled in the first half of 2026, with 1,164 suspects arrested and assets worth IDR1.75 trillion, approximately 105 million US dollars, seized, indicating that the financial-disruption strategy is running in parallel with continued criminal-enforcement activity rather than replacing it. The same P2SK Amendment materially expands OJK's crypto-supervisory reach. Effective 17 June 2026, Law No. 4 of 2026 gives OJK expanded supervisory and enforcement powers over crypto and digital financial-asset institutions, including authority to suspend or block non-compliant crypto transactions conducted by domestic or foreign parties, and creates a new statutory taxonomy for such institutions. This reinforces, at primary-law level, the OJK-Bappebti supervisory transfer completed in January 2025, and it means the single legislative instrument driving gambling-related financial disruption is simultaneously the instrument tightening crypto-market oversight. Indonesia's FATF standing remains unchanged. Indonesia is not on the FATF grey list, having secured full FATF membership in October 2023; no fresh plenary action affecting this status has surfaced this cycle. #### Cross-Monitor Connections The gambling-related mule-account disruption campaign connects directly to Advennt's gambling-regulatory tracking, where the same task force and enforcement statistics are read through a gambling-prohibition-enforcement lens rather than an AML-typology lens. It also connects to the crypto monitor's tracking of the P2SK Amendment's expansion of OJK's crypto-supervisory powers, since both developments trace to the identical statutory instrument. The scale of the PPATK-reported transaction flow, at approximately 17.3 billion US dollars across 12.3 million people in 2025, illustrates why financial-sector disruption has become a necessary complement to site-blocking: the underlying money flow is large enough that content-level enforcement alone could not meaningfully constrain it. #### Outlook Watch for the issuance of primary regulatory text for the P2SK task-force instrument itself, since current findings rest on secondary press reporting of an OJK Banking Forum announcement rather than a retrieved gazette text. Watch also for PPATK's own primary statistical release corroborating the IDR286.84 trillion 2025 transaction-flow figure. Indonesia's crypto-supervisory expansion under the same law is a structural development worth monitoring for follow-on AML-typology implications as OJK's suspend-or-block authority over foreign-party crypto transactions is tested in practice. Domain intelligence (D1–D8) #### Sanctions Indonesia's standing sanctions-enforcement posture this cycle is best read through the lens of domestic payment-channel interdiction rather than the cross-border designations architecture more typically associated with this category. A coordinated multi-agency initiative involving the Financial Services Authority, Bank Indonesia, the financial intelligence unit PPATK and the national police is pressing to sever payment pathways that have sustained illegal online gambling networks. Banks have reportedly been instructed to apply enhanced due diligence and to block accounts tied to these networks, with 39,923 accounts now blocked, an increase of 1,127 since the start of October 2026. Estimated turnover through these networks is put at roughly Rp86.8 trillion. The figures rest on officials' statements at a press conference relayed by independent media rather than on a primary regulatory instrument reached directly this cycle, which caps the finding at a probable rather than confirmed tier. Continue reading The architectural significance lies less in the specific account count than in what sustained freezing activity at this scale implies about the underlying vulnerability of retail payment rails to channeling illicit gambling proceeds, and in the coordinated character of the response across four separate agencies. A single-agency enforcement action against a gambling operator would be an incident; a standing inter-agency mechanism instructing banks fleet-wide to apply enhanced due diligence against a defined typology is closer to a structural countermeasure, and the trajectory recorded this cycle is escalating rather than episodic. Financial institutions with Indonesian retail payment exposure should treat the rising freeze count as an indicator of continuing regulatory appetite for intervention in this channel, independent of whether any single underlying gambling operation attracts its own enforcement notice. #### Outlook The trajectory to monitor is whether the freeze count continues its climb and whether a primary OJK, Bank Indonesia or PPATK instrument becomes available to substantiate the current press-sourced figures at a higher confidence tier. No sanctions-list or designation action is implicated by this finding; the relevant mechanism is domestic account-level interdiction rather than targeted financial sanctions in the FATF Recommendation 6 sense. This framing is intelligence-register orientation only and should not be read as predicting the outcome of any specific enforcement action. Judgment: Multi-agency coordination to sever gambling payment pathways and rising account-freeze counts signal escalating enforcement against domestic illicit payment flows. Probable #### Beneficial Ownership and Corporate Transparency The central structural finding in this domain for Indonesia is a compliance gap rather than a legislative gap. Presidential Regulation 13 of 2018 established a central beneficial-ownership registry administered by the Ministry of Law and Human Rights, requiring all corporate forms, including PT companies, Yayasan foundations, cooperatives and partnerships, to self-report beneficial-ownership data annually. Registry existence, however, outpaces practical transparency utility: fewer than 30 percent of registered corporations have complied with the mandatory reporting requirement, and the data that has been submitted is not independently verified. This is treated here as a structural enabler condition for PT and Yayasan opacity rather than an isolated compliance lapse, consistent with the architecture-over-incident framing applied throughout this baseline. This condition is treated as a stable structural feature of the Indonesian corporate-registry environment rather than a recent deterioration, since no baseline evidence indicates the compliance rate is moving in either direction this cycle. Continue reading A related scheme surfaced this cycle illustrates how registry-level opacity can combine with payment-system and crypto-rail layering. A shell-company network centred on PT A2Z Solusindo Teknologi laundered illegal-gambling proceeds through the Indonesian QRIS instant-payment system and cryptocurrency, moving funds through 4,656 bank accounts across 22 banks before disruption by Bareskrim, which seized roughly 32.1 million dollars. The underlying corporate-opacity and layering architecture behind the disrupted network is assessed as reproducible, since the beneficial-ownership verification gap that allowed shell entities to be established and operated with limited scrutiny has not itself been addressed by this single disruption. Standing architecture context frames how this Indonesia-specific finding should be read against the European transparency regime, even though Indonesia sits outside that regime perimeter. The EU AML Package now comprises three distinct instruments: the AML Regulation, known as the AMLR, under Regulation (EU) 2024/1624, which is directly applicable across member states without national transposition; the sixth AML Directive, known as 6AMLD, which each member state transposes individually into domestic law; and the AMLA Regulation under Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority. Together these instruments are shifting the EU beneficial-ownership and corporate-transparency supervisory perimeter from a purely national-authority model toward a hybrid regime in which AMLA holds direct supervisory authority over a defined set of higher-risk cross-border obliged entities, with indirect supervisory influence over the remainder through coordination with national supervisors. Indonesia, as a non-EEA jurisdiction, sits outside this AMLR, 6AMLD and AMLA Regulation perimeter entirely; its only EU-facing exposure channel is the high-risk third-country listing mechanism, under which it was neither added nor previously listed in the December 2025 update. This durable architectural backdrop is standing context for reading beneficial-ownership findings generally, not a Indonesia-specific development this cycle. This structural distinction between direct EU applicability and indirect national transposition is the backdrop against which any future Indonesia-specific high-risk-listing determination, positive or negative, would need to be read. #### Outlook No structural registry reform for Indonesia was identified this cycle, and the sub-30-percent compliance rate with unverified self-declared data is assessed as a stable, rather than improving or deteriorating, condition absent a dedicated verification mandate. The comparative claim that Indonesia operates the only central beneficial-ownership registry in Southeast Asia was noted in this baseline research pass but lacks independent regional comparative verification, and is flagged here as an open item for the next research cycle rather than an established regional-uniqueness finding. Firms onboarding Indonesian corporate or fund-structure counterparties should continue to treat self-declared beneficial-ownership filings on PT structures as unverified data points rather than assured records, pending either a domestic verification-capacity build-out or, at the EU-facing margin, any future change to the non-listed status of Indonesia under the high-risk third-country mechanism. Operations and Compliance teams handling Indonesian corporate onboarding should factor the absence of independent verification directly into their own beneficial-ownership confidence scoring rather than treating registry submission alone as a completed control. Judgment: No beneficial-ownership register development identified this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators The defining finding for Indonesia in this domain is a supervision-intensity gap concentrated in the designated non-financial businesses and professions sector, rather than in the banking sector proper. Notaries, lawyers and real-estate agents are legally obliged reporting entities under Government Regulation 61 of 2021, yet FATF assessment found that, taken overall, this DNFBP sector has not effectively implemented AML/CFT preventive measures. Remedial action taken against non-compliant DNFBPs has been overwhelmingly limited to warnings rather than licence-level penalties such as suspension or revocation. Under the enabler-jurisdiction filter, this combination, a legal obligation that exists on paper alongside an enforcement posture that stops short of penalties with real market consequence, is the structurally significant finding: it leaves the professional-enabler gatekeeper layer under-supervised relative to the own risk profile of Indonesia and relative to the banking sector, where supervisory intensity is comparatively higher. Continue reading This gatekeeper gap sits alongside, and plausibly compounds, the beneficial-ownership verification weakness addressed in the D2 domain. Notaries and lawyers are frequently the professionals of first contact in establishing PT and Yayasan corporate structures and administering the transactions, including real estate, in which laundered proceeds are placed; a gatekeeper layer that is under-supervised at the point of warnings-only enforcement compounds a registry layer where self-declared beneficial-ownership data is not independently verified. Neither condition alone fully explains observed laundering typologies in Indonesia, such as the extractive-industry and gambling-proceeds schemes addressed elsewhere in this baseline, but together they describe an enabler architecture in which professional facilitators face limited downside for inadequate implementation of preventive measures. Enablement as signal applies directly here: the absence of licence-level enforcement action against the DNFBP sector, despite a FATF assessment finding ineffective implementation, is itself analytically significant, distinct from and additional to any single enforcement episode that might occur in a future cycle. This baseline records no DNFBP licence suspension or revocation action in the research window, consistent with the warnings-only characterisation. Within the broader D3 coverage of FIM, spanning enabler ecosystems such as the United Kingdom professional-services sector, Dubai and the UAE, Singapore and the Swiss reform trajectory, this Indonesia baseline contributes a comparably structured enabler-jurisdiction assessment: a domestic legal obligation exists, but supervisory follow-through is thin. No comparative enforcement-intensity claim between Indonesia and these other standing D3 jurisdictions is made here; the finding is confined to what the evidence base of this cycle supports for Indonesia specifically. #### Outlook No legislative or supervisory reform to DNFBP oversight was identified as pending in this cycle research window, and the enforcement posture is assessed as structurally stable rather than actively evolving. The most likely channel through which this gap becomes visible in a future cycle is either a FATF fifth-round mutual evaluation assessment of the effectiveness of Indonesia DNFBP framework, tracked here alongside the broader mutual-evaluation-scheduling uncertainty in the D1 domain, or an individual enforcement escalation beyond the warnings-only pattern that would itself constitute a notable departure from the baseline finding. Firms relying on Indonesian notaries, lawyers or real-estate agents as introducers or transaction facilitators for higher-net-worth or corporate customers should weight this supervision-intensity gap into their own enhanced due-diligence posture rather than relying on the existence of a domestic reporting obligation as a proxy for effective gatekeeping. Judgment: No enabler-jurisdiction development identified this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity This domain baseline for Indonesia records a mixed trajectory: a substantial asset-recovery enforcement action in the extractive-industry corruption space, set against a persistent, structural under-investigation gap in a comparably significant proceeds-generating sector. In October 2025, six tin smelters and associated raw minerals, seized in the course of the Bangka Belitung tin-mining corruption probe and valued at roughly 362 to 422 million dollars, were formally handed over to state miner PT Timah. This is a significant enforcement episode against a standing extractive-industry money-laundering architecture that, per the active scheme inventory carried in this baseline, involves proceeds from corrupt allocation and under-reporting in the tin sector being laundered through banking, capital markets and real estate, at times routed offshore before repatriation. Read under the architecture-over-incident principle, the asset-recovery action updates the status of this scheme toward partial resolution without resolving the underlying laundering architecture itself, which remains only partially addressed. Continue reading Set against this, forestry and palm-oil predicate crime presents the inverse pattern: substantial proceeds generation without a commensurate enforcement response. The FATF 2023 mutual evaluation report flagged forestry crime as a major generator of criminal proceeds in Indonesia, yet money-laundering investigation and prosecution volume tied to forestry and palm-oil predicate crime remains persistently low relative to the scale of proceeds generated. A recent expansion of the Ministry of Environment and Forestry mandate to include money-laundering investigation authority has not yet closed this gap, per this baseline evidence. Under the three-pillar balance principle, this forestry gap deserves comparable analytical weight to the higher-profile tin-mining enforcement action, precisely because enforcement volume in the tin-mining case risks crowding out attention to the comparatively under-enforced forestry channel. The extractive-industry laundering architecture identified here also carries a corporate-transparency dimension: the active scheme inventory records this scheme as spanning both the D4 conflict-finance and extractive-industry domain and the D2 beneficial-ownership domain, reflecting the role that opaque corporate vehicles play in receiving and layering extractive-sector proceeds before any repatriation. This overlap reinforces the reading that domain-siloed enforcement reporting, an asset-recovery action recorded in isolation, understates the multi-domain nature of the underlying architecture. This baseline carries a preliminary severity assessment of HIGH for both the tin-mining and forestry-related schemes, reflecting the scale of proceeds and the enforcement gap respectively, though this remains a preliminary rather than final rating. Both findings carry direct cross-monitor relevance. The persistently low investigation volume for forestry and palm-oil proceeds is flagged as relevant to SCEM commodity-flow governance tracking, even absent an established direct armed-conflict financing linkage in this baseline evidence, while the PT Timah asset-recovery action and the PEP-adjacent extractive-sector allocation dynamics it surfaces warrant a state-capture-lens review under WDM, given the complicity of state officials in corrupt resource allocation implied by the underlying corruption probe. #### Outlook The near-term marker in this domain is whether asset-recovery momentum in the tin-mining case extends to the broader laundering architecture, banking, capital markets, real estate and offshore routing channels, that facilitated the underlying corruption, or whether the October 2025 handover represents the primary enforcement outcome of this particular episode. Separately, forestry and palm-oil money-laundering investigation volume is assessed as unlikely to shift materially without a dedicated capacity or mandate change beyond the recent Ministry of Environment and Forestry authority expansion; this baseline treats the investigation-volume gap as structurally stable rather than actively narrowing. Both threads should be read by Board and Risk audiences as extractive-industry integrity exposure that enforcement-episode reporting alone tends to understate. Judgment: No conflict-finance development identified this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Indonesia's crypto-asset integrity architecture has reached a structural turning point this cycle. Law No. 4 of 2026, amending the 2023 P2SK (financial sector development and strengthening) law, completes the transfer of crypto-asset regulatory supervision from the commodity-futures regulator Bappebti to the Financial Services Authority, OJK, and in doing so treats crypto-asset businesses as financial institutions rather than commodity-exchange participants. This is a reclassification with direct financial-integrity consequence, because financial-institution status is the conceptual gateway through which AML/CTF obligations, customer due diligence standards, and suspicious-transaction reporting duties are conventionally extended in Indonesian law. Framed through the lens of the typology this domain tracks, structural transfer of supervisory authority over a previously commodity-regulated asset class is the kind of durable architectural change that matters more than any single enforcement action against an individual exchange, because it resets the baseline against which every future crypto-related finding in Indonesia will be read. Continue reading What the current material does not yet establish is implementation. No newly dated AML-specific implementing circular, such as a PPATK or OJK regulation setting out customer due diligence thresholds, registration conditions, or reporting triggers specific to crypto-asset operators under their new financial-institution classification, was located within the present research window. This is an honest gap rather than an assessment that no such instrument exists: the primary-law change is confirmed, but the operational detail that would let a reader judge how strictly the new perimeter will be policed is, for now, absent from the register. The practical effect is that Indonesia's crypto-asset AML exposure should be read as a jurisdiction in transition: the legal classification has moved, the enforcement infrastructure giving that classification teeth has not yet been observed to follow, and the interval between the two is itself the thing worth watching. This observation sits consistently with Indonesia's broader AML/CTF posture, which this cycle is otherwise stable: an FATF member outside the grey list, with its Recommendation 6 rating recently upgraded to Compliant on the strength of PPATK Decree 670 of 12 December 2025. That decree's subject matter, targeted financial sanctions relating to terrorism, is a different compliance domain from crypto-asset supervision, but its existence demonstrates that Indonesia's AML architecture is capable of producing dated, specific implementing instruments when it chooses to close a flagged gap. Whether a comparable instrument follows for the crypto-asset transfer, and on what timeline, is the open question this domain carries into the next cycle. The transfer also has a bearing on how proceeds of predicate offences might move through Indonesia's financial system going forward. Indonesia's ongoing bank-account disruption campaign against accounts linked to online gambling, which has subjected approximately 38,796 accounts to enhanced due diligence or blocking according to reporting from early October 2026, illustrates that Indonesian authorities are willing to act at scale against suspected illicit-finance activity routed through regulated banking rails. Whether a parallel posture extends to crypto-asset rails now that such firms sit within OJK's financial-institution perimeter is not something the current material speaks to directly, but the existence of an active enforcement precedent against bank-rail misuse is a relevant backdrop against which the crypto transfer's eventual implementation will be read. #### Outlook The central question for this domain going into the next cycle is whether the structural transfer to OJK is followed, and on what timeline, by implementing rules that give the new financial-institution classification operational AML content. Until such a rule or circular is located and confirmed, the finding should be read as a durable change in legal architecture whose practical supervisory weight remains undetermined. A reader tracking Indonesia's crypto-asset integrity exposure should treat the primary-law transfer as confirmed and treat any claim about enhanced due diligence, registration, or reporting obligations specific to crypto firms as unconfirmed until a dated implementing instrument is identified. As scheduled, the natural checkpoint for this question is whichever OJK or PPATK rulemaking cycle follows the P2SK amendment; no specific date for such a follow-on instrument is available in the current material. Judgment: OJK's PADK 3/2026 reporting regime and the 2026 Omnibus Law's freeze/block powers continue to sharpen the supervisory toolkit over digital-asset activity; next operative deadline is 10 Nov 2026. Probable #### Compliance Technology and Active Defence The defining finding in this domain is a demonstrated translation of RegTech and SupTech capability into prosecution-ready evidentiary outcomes, rather than a compliance-technology deployment assessed only on adoption grounds. The PPATK SIPENDAR platform provides near-real-time data-sharing between financial institutions and law enforcement, and has been paired with blockchain-tracing tools built with UNODC support since March 2024. This combined capability underpins the three 2024 to 2025 convictions of individuals financing Syria-based terrorism through cryptocurrency, in which on-chain wallet evidence was admitted at trial, a concrete instance of active-defence technology functioning as an enforcement input rather than a reporting-compliance checkbox. Continue reading This baseline also surfaces two evidentiary-quality findings that qualify how the Indonesia profile as a whole should be read by downstream users. First, this baseline relies heavily on FATF, UNODC and international-vendor English-language reporting; no direct Bahasa Indonesia primary PPATK, OJK or Bank Indonesia publication was independently retrieved during this research cycle. This creates a downstream reasoning risk of over-relying on FATF or vendor characterisations of Indonesian regulatory text rather than the underlying primary Indonesian-language sources themselves, a gap flagged for prioritisation in future research cycles. Second, and more immediately consequential for publication readiness, an automated challenge review of this baseline returned a hold-for-review verdict: one hard flag, concerning the stale CoFTRA sectoral-supervisor reference corrected elsewhere in this baseline; two soft flags, concerning the omission of the June 2026 FATF follow-up report outcome from the profile summary narrative fields, and an unverified claim that Indonesia operates the only Southeast Asian beneficial-ownership registry of its kind; and one information finding. This verdict means the standing Indonesia baseline profile record is pending correction rather than fully clean, and downstream Composer and Reviewer stages should treat it accordingly. Read together, these two findings, a genuine compliance-technology capability success and an unresolved evidentiary-quality hold, illustrate why active-defence assessment in this domain must track both the sophistication of the detection and disruption tooling of a jurisdiction and the reliability of the evidentiary base underpinning the assessment of that jurisdiction more broadly. #### Outlook The most direct near-term marker in this domain is procedural: whether the hard-flag and soft-flag findings of the automated challenge review are resolved through a re-issued, source-verified baseline synthesis pass before this Indonesia profile is relied upon downstream without qualification. Absent that correction, the CoFTRA sectoral-supervisor reference and the FATF follow-up report summary-field omission remain live data-quality gaps in the standing profile even though the corrected facts are already available in the structured claims for this cycle. On the capability side, SIPENDAR and blockchain-tracing capability are assessed as a stable, functioning enforcement input rather than a pending development, and no further RegTech or SupTech capability expansion was identified as scheduled in this cycle research window. Future research cycles prioritising direct Bahasa Indonesia primary-source retrieval would meaningfully strengthen the evidentiary tier of this domain assessment. Judgment: No RegTech/compliance-technology development identified this cycle. Uncertain #### AML/CTF Regime Indonesia's AML/CTF-adjacent enforcement posture has escalated materially this cycle through the formalisation of a cross-agency task force under Law No. 4 of 2026, the P2SK Amendment. The task force links Komdigi, OJK and Bank Indonesia specifically to disrupt mule bank accounts used to fund illegal online gambling, on the explicit premise that content-level site-blocking, which had already actioned approximately 3.7 million sites and pieces of content since October 2024, was insufficient on its own. Approximately 38,000 accounts have been referred to OJK for suspected gambling-related activity, of which 32,500 have been closed. This account-closure activity represents a concrete, financial-institution-facing enforcement mechanism layered on top of Indonesia's existing content-blocking apparatus. Continue reading The scale of the underlying money flow that this task force is designed to address is substantial: Indonesia's financial intelligence unit, PPATK, reported IDR286.84 trillion, approximately 17.3 billion US dollars, in online-gambling-linked transactions in 2025, spanning more than 422 million transactions and approximately 12.3 million people. Read alongside the National Police's disclosure of 718 illegal online-gambling cases handled in the first half of 2026, with 1,164 suspects arrested and IDR1.75 trillion in assets seized, the picture is one of a coordinated, multi-agency enforcement escalation across financial, criminal and regulatory channels simultaneously. Indonesia's standing FATF status is unchanged: it is not on the FATF grey list, having secured full FATF membership in October 2023, so this escalation is occurring against a backdrop of an otherwise stable international AML standing rather than in response to FATF pressure. No T1 primary text of the task-force instrument itself has been retrieved; the finding rests on multiple independent T3 press reports of a July 2026 OJK Banking Forum announcement. #### Outlook Watch for primary regulatory or gazette text formalising the task force's operating mandate, and for PPATK's own primary statistical publication corroborating the IDR286.84 trillion transaction-flow figure reported this cycle through secondary sources. The account-closure rate, currently 32,500 of approximately 38,000 referred accounts, is a concrete metric to track for evidence of whether the financial-disruption strategy is sustaining momentum or plateauing. Judgment: Indonesia remains a full FATF member, not grey-listed, with a June 2026 follow-up report crediting a December 2025 decree for a technical-compliance upgrade. Probable #### Commercial Activity Indonesia's crypto-asset and fintech sector saw a concentrated wave of foreign-entry M&A and investment within the window. Bybit completed a majority-stake acquisition of PT Enkripsi Teknologi Handal, known as NOBI, rebranding the entity Bybit Indonesia. Robinhood Markets agreed to acquire PT Buana Capital Sekuritas and PT Pedagang Aset Kripto, a transaction subject to OJK change-in-control review with status currently unresolved. ICEx Group raised approximately IDR 1 trillion, roughly 70 million US dollars, with eleven major Indonesian exchanges as founding shareholders, and was subsequently licensed by OJK as the country's second official crypto exchange. OSL took a 15 million dollar stake in Evergreen Crest, and 01F Group confirmed an investment in DANA, Indonesia's digital-wallet leader. Continue reading Read as integrity infrastructure rather than as ordinary market news, this wave of named-party, largely disclosed transactions corroborates continued investor confidence in operating within the OJK-regulated perimeter rather than around it: every named acquirer and target in this cycle's developments is proceeding through, or has already cleared, an OJK licensing or change-in-control process, rather than establishing an unregulated parallel channel. The one transaction with disclosed financial terms, ICEx Group's capital raise, demonstrates that OJK licensing can coexist with large-scale domestic exchange consolidation; the two pending or undisclosed-amount transactions, Bybit/NOBI and Robinhood/Buana Capital, illustrate that foreign strategic entry is proceeding at the same time, with regulatory review as the open variable. #### Outlook The Robinhood transaction's OJK change-in-control review is the clearest near-term signal of how the regulator is treating foreign consolidation in the licensed crypto-asset and brokerage space. Continued disclosed and undisclosed-amount consolidation at this pace would be worth tracking against OJK's capacity to review and approve change-in-control applications in a timely manner. Judgment: No commercial activity among integrity-infrastructure firms concerning Indonesia identified this cycle. Uncertain Regulatory horizon In Force Pending 10 Nov 2026 · ±quarter ### POJK 23/2025 transitional deadlines (system-control ownership, customer-fund placement) Deadline for required ownership/control of certain systems and amended customer-fund placement mechanisms under POJK 27/2024 as amended by POJK 23/2025. [Source](https://cryptoslate.com/crypto-laws/jurisdiction/indonesia/) Proposed 2027 · ±multi_year ### Indonesia National Risk Assessment (NRA) refresh A refreshed NRA would recalibrate Indonesia's stated ML/TF/PF threat profile amid the current online-gambling and crypto-perimeter enforcement expansion. [Source](https://www.ppatk.go.id/publikasi.html) Proposed 2027-Q1 · ±multi_year ### OJK 2026-2031 digital-finance and crypto-oversight roadmap OJK intends to set multi-year regulatory priorities for fintech, digital financial assets and crypto, potentially broadening the current trading-focused perimeter. [Otoritas Jasa Keuangan (OJK) Source](https://www.mlex.com/mlex/financial-services/articles/2519451) 3 dated · 3 pending date · baseline fim-2026-07-05 Role action cards MLRO ### Account-freeze volumes tied to illegal online gambling flows continue to climb across Indonesian banks. A rising multi-agency account-blocking count against gambling-linked flows signals continued pressure on institutions to apply enhanced due diligence to this specific typology, with the enforcement trajectory assessed as escalating rather than stable. 1 evidence refs Compliance ### Multi-agency coordination on gambling-linked payment accounts is intensifying in Indonesia. The joint OJK, Bank Indonesia, PPATK and police initiative reflects a structural tightening of expectations around enhanced due diligence for gambling-adjacent accounts, alongside a standing FATF compliance position that remains largely favorable. 2 evidence refs Legal ### No sanctions-designation action is implicated by this cycle's gambling-payment enforcement activity. The enforcement mechanism in play is domestic account-level interdiction rather than targeted financial sanctions, and Indonesia's FATF standing remains free of increased-monitoring listing. 2 evidence refs Board ### Indonesian authorities are escalating coordinated action against illegal-gambling payment flows while the country's overall AML/CTF standing remains stable. The combination of intensifying domestic enforcement and a stable, broadly compliant FATF position frames a jurisdiction where enforcement risk in a specific channel is rising even as the general regulatory relationship with the institution remains unchanged. 2 evidence refs CTO ### No material change for this persona this cycle. No material change for this persona this cycle Risk ### Gambling-linked payment flows remain a live exposure concentration in the Indonesian retail banking channel. The scale of turnover estimated to have moved through gambling networks, set against rising but still-partial account freezes, indicates a persistent exposure concentration in retail payment accounts that warrants continued monitoring attention. 1 evidence refs Operations ### Enhanced due diligence instructions tied to gambling-linked accounts are an active operational requirement in Indonesia. Banks have reportedly been instructed to apply enhanced due diligence checks and block identified accounts, implying an ongoing operational screening and blocking workflow against this specific typology. 1 evidence refs Audit ### No material change for this persona this cycle. No material change for this persona this cycle Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity watch T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 6 Oct 2025 - 1 Jun 2025 - 19 Jun 2026 - 15 Sep 2025 - 28 May 2025 - OJK ordered blocking of 1,000 additional bank accounts used to fund online gambling, bringing the cumulative total blocked/EDD-flagged to 33,252 since 2024. 13 Apr 2026 - Task force collected IDR 2.34 trillion (~USD 139.7m) in administrative fines from 20 palm-oil firms and one nickel miner for illegal operations in forest areas. 24 Dec 2025 - 5 Aug 2026 - Six tin smelters and associated raw minerals seized during a large-scale corruption probe into illegal tin mining were formally handed to state miner PT Timah, consolidating an asset-recovery outcome from the wider Timah corruption case. 6 Oct 2025 - Following joint PPATK-police financial intelligence and on-chain tracing, Indonesian authorities identified and secured convictions of three individuals for terrorism financing conducted through cryptocurrency transfers to Syria-based fundraising campaigns. 1 Jun 2025 - FATF adopted a follow-up report re-rating Indonesia's Recommendation 6 (terrorism-financing targeted financial sanctions) from Partially Compliant to Compliant, reflecting PPATK Decree 670 of 2025's tightened DTTOT listing standard. 19 Jun 2026 - Police arrested two suspects for laundering illegal-gambling proceeds via QRIS and cryptocurrency using a shell-company network and thousands of bank accounts, active in gambling since 2007 and laundering since 2019. 15 Sep 2025 - FATF adopted a follow-up report re-rating Indonesia's Recommendation 7 (proliferation-financing TFS) from Partially Compliant to Largely Compliant, recognising amendments to the PF Joint Regulation extending prohibitions on funding designated WMD-list persons. 28 May 2025 ### Sanctions changes - 12 Dec 2025 - PPATK Decree 670 of 2025, enacted 12 December 2025, introduced an explicit requirement for the DTTOT Task Force and National Police to apply a 'reasonable basis' evidentiary standard when proposing domestic terrorist-list (DTTOT) designations, replacing an implicit practice previously flagged as a technical deficiency by FATF's 2023 MER. 12 Dec 2025 - The European Commission's December 2025 update to its AML high-risk third-country list (Delegated Regulations (EU) 2026/46 and (EU) 2026/83) added Bolivia and the British Virgin Islands and delisted six African jurisdictions, while Indonesia was neither added nor previously listed, confirming continued non-listed status under the EU regime. 4 Dec 2025 - Indonesia's PF Joint Regulation framework, as reaffirmed in FATF's May 2025 follow-up review, continues to require designation of all UNSCR 2231 (Iran) and DPRK-related WMD-list individuals/entities to PPATK's national WMD list, with electronic communication of listing/freezing/delisting actions to supervised sectors. 28 May 2025 ### Regulatory horizon (register) - Indonesia National Risk Assessment (NRA) refresh - OJK 2026-2031 digital-finance and crypto-oversight roadmap - OJK draft POJK on Financial Reporting Integrity for fintech and crypto providers - POJK 23/2025 transitional deadlines (system-control ownership, customer-fund placement) - OJK completion of crypto licensing regime transition from Bappebti - Indonesia's next FATF follow-up report or 5th-round mutual evaluation - Bank Indonesia digital rupiah CBDC development continues ### Active schemes - Indonesian nationals sympathetic to ISIS/JAD-affiliated networks solicit and transfer cryptocurrency to Syria-based terrorism fundraising campaigns, sometimes laundered through humanitarian-aid fronts; PPATK/Detachment 88 pair SIPENDAR data-sharing with blockchain tracing to build prosecution-ready cases. - Shell companies place, receive and move illegal-gambling funds via Indonesia's QRIS instant-payment system and cryptocurrency, layering proceeds through thousands of bank accounts before integration into bonds and financial instruments; core vehicle PT A2Z Solusindo Teknologi. - Proceeds from corrupt allocation and under-reporting in tin (Bangka Belitung) and forestry/palm-oil sectors are laundered through banking, capital markets and real estate, sometimes routed offshore before repatriation; October 2025 asset-recovery action seized smelters and raw minerals. - Indonesia's central BO registry requires annual self-reporting by all corporate forms, but under-30% compliance and lack of independent verification allow PT structures to obscure ultimate ownership. - Notaries, lawyers and real-estate agents are obliged reporting entities but implementation of AML/CFT measures lags Indonesia's risk profile, with remedial action limited to warnings. Sources - [Counter Terrorism Designations and Update | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240815) - [https://www.ahp.id/indonesia-updates-beneficial-ownership-disclosure-rules-major-changes-that-will-affect-every-business/](https://www.ahp.id/indonesia-updates-beneficial-ownership-disclosure-rules-major-changes-that-will-affect-every-business/) - [https://www.letsmoveindonesia.com/business-registration-update-in-indonesia-update-ahu-corporate-data-or-risk-being-declared-inactive/](https://www.letsmoveindonesia.com/business-registration-update-in-indonesia-update-ahu-corporate-data-or-risk-being-declared-inactive/) - [https://www.reccessary.com/en/news/indonesia-forest-fine](https://www.reccessary.com/en/news/indonesia-forest-fine) - [https://www.reccessary.com/en/news/indonesia-47-companies-mining-palm-oil-illegal-deforestation](https://www.reccessary.com/en/news/indonesia-47-companies-mining-palm-oil-illegal-deforestation) - [https://www.ahp.id/consumer-protection-under-the-amended-p2sk-law-law-4-2026-expanded-scope-stronger-enforcement/](https://www.ahp.id/consumer-protection-under-the-amended-p2sk-law-law-4-2026-expanded-scope-stronger-enforcement/) - [https://www.blockhead.co/2026/06/30/indonesias-crypto-crackdown-meets-oecds-asian-regulatory-gap-report/](https://www.blockhead.co/2026/06/30/indonesias-crypto-crackdown-meets-oecds-asian-regulatory-gap-report/) - [https://www.marketing-interactive.com/indonesia-broadens-online-gambling-crackdown-with-banking-sector-at-the-centre](https://www.marketing-interactive.com/indonesia-broadens-online-gambling-crackdown-with-banking-sector-at-the-centre) - [https://fincrimecentral.com/indonesia-fatf-technical-compliance-upgrade/](https://fincrimecentral.com/indonesia-fatf-technical-compliance-upgrade/) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Indonesia-fur-2025.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Indonesia-fur-2025.html) - [https://www.ppatk.go.id/publikasi/read/196/anti-money-laundering-and-counter-terorist-financing-measures-indonesia.html](https://www.ppatk.go.id/publikasi/read/196/anti-money-laundering-and-counter-terorist-financing-measures-indonesia.html) - [https://www.oecd.org/en/publications/2026/03/anti-corruption-and-integrity-outlook-2026-country-notes_b1df9263/indonesia_f62cee7b.html](https://www.oecd.org/en/publications/2026/03/anti-corruption-and-integrity-outlook-2026-country-notes_b1df9263/indonesia_f62cee7b.html) - [https://www.lexology.com/library/detail.aspx?g=fa933c88-9dff-49fd-ae5e-dc6550f63069](https://www.lexology.com/library/detail.aspx?g=fa933c88-9dff-49fd-ae5e-dc6550f63069) - [https://www.mundovideo.com.co/en/asia/indonesia-blocks-gambling-accounts-and-tightens-full-control-of-online-betting-in-2026/](https://www.mundovideo.com.co/en/asia/indonesia-blocks-gambling-accounts-and-tightens-full-control-of-online-betting-in-2026/) - [https://agbrief.com/news/indonesia/17/07/2026/indonesia-blocks-3-7m-gambling-sites-closes-32500-bank-accounts/](https://agbrief.com/news/indonesia/17/07/2026/indonesia-blocks-3-7m-gambling-sites-closes-32500-bank-accounts/) - [https://www.mlex.com/mlex/financial-services/articles/2501236](https://www.mlex.com/mlex/financial-services/articles/2501236) - [https://www.abnrlaw.com/news/indonesias-p2sk-law-amendment-what-law-42026-changes-for-crypto-and-digital-financial-assets](https://www.abnrlaw.com/news/indonesias-p2sk-law-amendment-what-law-42026-changes-for-crypto-and-digital-financial-assets) - [https://www.fluxforce.ai/jurisdictions/indonesia](https://www.fluxforce.ai/jurisdictions/indonesia) - [https://www.mlex.com/mlex/financial-services/articles/2519451](https://www.mlex.com/mlex/financial-services/articles/2519451) - [PPATK](https://www.ppatk.go.id/siaran_pers/read/1642/judi-online-membajak-piala-dunia-2026-deposit-tembus-rp-1-triliun.html) - [FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/indonesia-fur-2026.pdf.coredownload.inline.pdf) - [ANTARA News](https://en.antaranews.com/news/433821/ri-continues-blocking-gambling-content-to-curb-transnational-networks) - [https://businesshubasia.com/ultimate-beneficial-ownership/](https://businesshubasia.com/ultimate-beneficial-ownership/) - [https://globallawexperts.com/who-is-a-beneficial-owner-in-indonesia/](https://globallawexperts.com/who-is-a-beneficial-owner-in-indonesia/) - [https://sigma.world/news/indonesia-use-id-numbers-illegal-betting/](https://sigma.world/news/indonesia-use-id-numbers-illegal-betting/) - [https://amluae.com/what-are-fatf-blacklist-and-grey-list-countries/](https://amluae.com/what-are-fatf-blacklist-and-grey-list-countries/) - [https://www.tradingview.com/news/cointelegraph:a6b1c0972094b:0-crypto-exchange-bybit-launches-in-indonesia-after-nobi-acquisition/](https://www.tradingview.com/news/cointelegraph:a6b1c0972094b:0-crypto-exchange-bybit-launches-in-indonesia-after-nobi-acquisition/) - [https://fintech.global/2026/09/21/01f-group-backs-dana-in-indonesia-fintech-push/](https://fintech.global/2026/09/21/01f-group-backs-dana-in-indonesia-fintech-push/) - [https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/indonesia-fur-2026.pdf.coredownload.inline.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/indonesia-fur-2026.pdf.coredownload.inline.pdf) - [https://focusgn.com/asia-pacific/indonesia-online-gambling-bank-accounts](https://focusgn.com/asia-pacific/indonesia-online-gambling-bank-accounts) - [https://en.tempo.co/read/2111525/why-danantara-monitor-wants-fatf-to-review-indonesia](https://en.tempo.co/read/2111525/why-danantara-monitor-wants-fatf-to-review-indonesia) - [https://www.hbtlaw.com/insights/2026-09/indonesia-reshapes-digital-asset-and-cryptocurrency-framework-with-2026-financial-services-omnibus-law](https://www.hbtlaw.com/insights/2026-09/indonesia-reshapes-digital-asset-and-cryptocurrency-framework-with-2026-financial-services-omnibus-law) - [https://www.anqacompliance.com/aml-indonesia-apg/](https://www.anqacompliance.com/aml-indonesia-apg/) - [FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Indonesia-Follow-Up-Report-2025.pdf.coredownload.inline.pdf) - [Sentinel.gi](https://sentinel.gi/jurisdictions/indonesia/) - [Global Gaming Insider](https://globalgaminginsider.com/news/7696/indonesia-ojk-orders-action-against-38796-accounts-linked-to-online-gambling) - [Nusantara DFDL](https://www.nusantaradfdl.com/insights/crypto-assets-in-indonesia/) - [Tempo](https://en.tempo.co/read/2111525/why-danantara-monitor-wants-fatf-to-review-indonesia) - [https://en.antaranews.com/news/440615/indonesia-cracks-down-on-online-gambling-targets-39923-accounts](https://en.antaranews.com/news/440615/indonesia-cracks-down-on-online-gambling-targets-39923-accounts) - [https://complead.ai/resources/whitepapers/aml-in-indonesia](https://complead.ai/resources/whitepapers/aml-in-indonesia) - [Statute of the International Court of Justice | United Nations](https://www.un.org/en/about-us/un-charter/statute-of-the-international-court-of-justice) - [English | SYSTEM OF ADMINISTRATION OF JUSTICE](https://www.un.org/internaljustice/oaj/en/languages/english?block_config_key=jhGC8HKh4TRE4PK5o8lVZwkqxyEVXwyUUs9M2QsgrDo&page=238) - [1 - This text is informal and based on the resolutions adopted by](https://www.un.org/en/internaljustice/pdfs/UNDT_Statute.pdf) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [OLA/COD/2394 Office of Legal Affairs Codification Division Handbook on the](https://legal.un.org/cod/books/handbookonpsd.pdf) - [Choice of procedure](https://www.un.org/Depts/los/settlement_of_disputes/choice_procedure.htm) - [GE. Report of the detailed findings of the independent](https://www.un.org/unispal/wp-content/uploads/2015/06/cb361dbaf1526e5785257e6c004b1e94_20150622%20--%20OHCHR%20Report%20on%20Palestine%20[A_HRC_CRP_4].pdf) - [2022-UNAT-1192 | SYSTEM OF ADMINISTRATION OF JUSTICE](https://www.un.org/internaljustice/oaj/en/judgment/2022-unat-1192) - [Without Clear Definition, Universal Jurisdiction Principle Risks Misuse, Abuse, Sixth Committee Speakers Warn | UN Meetings Coverage and Press Releases](https://press.un.org/en/2018/gal3571.doc.htm) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Indonesia's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Indonesia-fur-2025.html) - [Mutual Evalation Report of Indonesia](https://www.fatf-gafi.org/en/countries/d-i/indonesia/documents/mutualevalationreportofindonesia.html) - [Indonesia](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/Indonesia-Follow-Up-Report-2025.pdf.coredownload.inline.pdf) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Indonesia's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Mutualevaluations/MER-Indonesia-2023.html) - [Advisory on the FATF–Identified Jurisdictions with AML/CFT Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/advisory-fatf-identified-jurisdictions-amlcft-deficiencies) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/APG-Mutual-Evaluation-Report-Indonesia.pdf) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [April 2023 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Mutual-Evaluation-Report-Indonesia-2023.pdf.coredownload.inline.pdf) - [Anti-money laundering and counter-terrorist financing measures Indonesia](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evaluation-Report-Indonesia.pdf.coredownload.inline.pdf) - [Page 1 of 5 STEP-BY-STEP GUIDE FOR ASSET RECOVERY FROM G20 COUNTRIES INDONESIA](https://www.unodc.org/documents/corruption/G20-Anti-Corruption-Resources/G20-Step-by-step-guides-on-nternational-cooperation-and-asset-recovery/Asset-Recovery-Guides/Indonesia.pdf) - [Indonesia's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/MER-Indonesia-2023.html) - [Indonesia](https://www.fatf-gafi.org/en/countries/detail/Indonesia.html) - [Recovering stolen assets](https://www.unodc.org/roseap/en/indonesia/report/2025/recovering-stolen-assets.html) - [Assessing the Digital Financial Threat Landscape in Indonesia](https://www.unodc.org/roseap/en/what-we-do/anti-corruption/topics/2022/03-assessing-digital-financial-threat-landscape-indonesia.html) - [Fatf-gafi](https://www.fatf-gafi.org/content/dam/fatf/documents/reports/mer-fsrb/APG-Mutual-Evaluation-Report-Indonesia.pdf) - [Global Crypto Policy Review & Outlook 2024/2025 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2024-25-report) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Changing of the guard in Indonesia: what is the impact for crypto firms?](https://www.elliptic.co/blog/analysis/changing-of-the-guard-in-indonesia-what-is-the-impact-for-crypto-firms) - [Crypto regulatory affairs: The US Treasury’s intense week of crypto-related sanctions actions](https://www.elliptic.co/blog/crypto-regulatory-affairs-the-us-treasurys-intense-week-of-crypto-related-sanctions-actions) - [Indonesia Country Guide | Elliptic](https://www.elliptic.co/country-guides/indonesia) - [Changing of the Guard in Indonesia: What is the Impact For Crypto Firms? | Elliptic Connect](https://hub.elliptic.co/analysis/changing-of-the-guard-in-indonesia-what-is-the-impact-for-crypto-firms/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Global crypto regulation review 2025](https://www.elliptic.co/resources/global-crypto-regulation-review-2025) - [Targeted Update on Implementation of the FATF Standards on Virtual Assets and](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/2025-Targeted-Upate-VA-VASPs.pdf.coredownload.pdf) - [Promoting Beneficial Ownership Disclosure in Indonesia](https://www.unodc.org/roseap/en/what-we-do/anti-corruption/topics/2021/05-beneficial-ownership-disclosure-indonesia.html) - [Public-Private Dialogue on Beneficial Ownership and Transparency](https://www.unodc.org/roseap/what-we-do/anti-corruption/topics/2022/18-beneficial-ownership-indonesia.html) - [Beneficial Ownership Regulations and Company Registries in Southeast Asia](https://www.unodc.org/roseap/uploads/documents/topics/anti-corruption/2022/Beneficial_ownership_regulations_and_company_registries_in_Southeast_Asia.pdf) - [Strengthening Beneficial Ownership Investigations in Indonesia](https://www.unodc.org/roseap/en/what-we-do/anti-corruption/topics/2021/17-beneficial-ownership-investigations-indonesia.html) - [Implementation of Beneficial Ownership Transparency in ASEAN Member States and](https://www.unodc.org/roseap/uploads/documents/Publications/2024/Implementation_of_Beneficial_Ownership_Transparency_in_ASEAN_Member_States_and_Timor-Leste.pdf) - [UN DESA Policy Brief No. 148: Beneficial ownership information: Supporting fair taxation and financial integrity | UN DESA Publications](https://desapublications.un.org/policy-briefs/un-desa-policy-brief-no-148-beneficial-ownership-information-supporting-fair-taxation) - [Directory of Open-Source Registries: Indonesia](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/indonesia.html) - [BEST PRACTICES ON BENEFICIAL OWNERSHIP FOR LEGAL PERSONS OCTOBER 2019](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Best-Practices-Beneficial-Ownership-Legal-Persons.pdf) - [How Indonesian Law Enforcement Used On-chain Intelligence to Secure Convictions for Terrorism Financing | TRM Blog](https://www.trmlabs.com/resources/blog/how-indonesian-law-enforcement-used-on-chain-intelligence-to-secure-convictions-for-terrorism-financing) - [Executive Summary](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Executive-Summary-Mutual-Evaluation-Report-Indonesia-2023.pdf.coredownload.inline.pdf) - [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html) - [1 STATEMENT BY MR. ANDHIKA CHRISNAYUDHANTO, DEPUTY FOR INTERNATIONAL](https://www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/statement_of_indonesia_on_open_briefing_ctc_14_feb_2022_0.pdf) - [Jamaah Ansharut Daulah | Security Council](https://main.un.org/securitycouncil/en/content/jamaah-ansharut-daulah) - [Indonesia Hands Over Six Seized Tin Smelters to State Miner - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-06/indonesia-hands-over-six-seized-tin-smelters-to-state-miner) - [Indonesia strengthens financial investigation capabilities to fight corruption](https://www.unodc.org/roseap/en/indonesia/2025/02/financial-investigation-fight-corruption/story.html) - [FATF releases detailed guidance to help practitioners recover criminal assets](https://www.fatf-gafi.org/en/publications/Methodsandtrends/asset-recovery-guidance-best-practices-2025.html) - [Corruption - Definition and Facts | United Nations in Indonesia](https://indonesia.un.org/en/308676-corruption-definition-and-facts) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [SANCTIONS ADVISORY - Guidance for Shipping and ...](https://ofac.treasury.gov/media/934236/download?inline=) - [EU's 20th Russia Sanctions Package](https://www.chainalysis.com/blog/eu-russia-sactions-package-april-2026/) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251218) - [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626) - [Crypto Sanctions: 2026 Crypto Crime Report](https://www.chainalysis.com/blog/crypto-sanctions-2026/) - [Additional Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/other-ofac-sanctions-lists) - [Mutual Evalation Report of Indonesia](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevalationreportofindonesia.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [Panama](https://www.fatf-gafi.org/en/countries/detail/Panama.html) - [Outcomes FATF Plenary, 22-24 February 2023](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-february-2023.html) - [Asia/Pacific Group on Money Laundering (APG)](https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html) - [Angola](https://www.fatf-gafi.org/en/countries/detail/Angola.html) - [Outcomes FATF Plenary, 25-27 October 2023](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-october-2023.html) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [11304/26 ADD 9 COMPET.3 Council of the European Union Delegations will find attached document COM(2026) 341 annex. Encl.: COM(20](https://data.consilium.europa.eu/doc/document/ST-11304-2026-ADD-9/en/pdf) - [EN EN EUROPEAN COMMISSION Brussels, 4.5.2026 COM(2026) 191 final](https://environment.ec.europa.eu/document/download/a3c5c3a0-232e-43c4-b0b8-1eecb1df45c7_en?filename=Report+from+the+Commission+to+the+Council+and+Parliament+on+the+EUDR.pdf) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [Indonesia Targets Gambling Ring Using Crypto, QR Codes | OCCRP](https://www.occrp.org/en/news/indonesia-targets-gambling-ring-using-crypto-qr-codes) - [U.S. Crackdown on Southeast Asian Crypto Scam Centers](https://www.chainalysis.com/blog/asian-scam-centers-crypto-fraud-april-2026/) - [The Chinese-language Underground Crypto Money Laundering Ecosystem](https://www.chainalysis.com/blog/2026-crypto-money-laundering/) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [Responding to emerging crimes](https://www.unodc.org/roseap/en/indonesia/report/2025/responding-to-emerging-crimes.html) - [Indonesia](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/indonesia-fur-2026.pdf.coredownload.inline.pdf) - [Counter Terrorism Designation | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20220203) - [Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20220509) - [Counter Terrorism Designations and Update | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240815) - [FATF (Asia/Pacific Group on Money Laundering assessment)](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Mutual-Evaluation-Report-Indonesia-2023.pdf.coredownload.inline.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Indonesia-fur-2025.html) - [FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fur/indonesia-fur-2026.pdf.coredownload.inline.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [UNODC Regional Office for Southeast Asia and the Pacific](https://www.unodc.org/roseap/what-we-do/anti-corruption/topics/2022/18-beneficial-ownership-indonesia.html) - [TRM Labs](https://www.trmlabs.com/resources/blog/how-indonesian-law-enforcement-used-on-chain-intelligence-to-secure-convictions-for-terrorism-financing) - [OCCRP](https://www.occrp.org/en/news/indonesia-targets-gambling-ring-using-crypto-qr-codes) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-10-06/indonesia-hands-over-six-seized-tin-smelters-to-state-miner) - [Chainalysis](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) Coverage gaps fim-int-2026-07-05-G001: No direct Bahasa Indonesia-language… fim-int-2026-07-05-G001: No direct Bahasa Indonesia-language primary source retrieval (PPATK annual reports, OJK circular letters, Bank Indonesia regulations) was conducted this cycle; future research should prioritise native-language primary documents. [resolved] fim-int-2026-07-05-G002: The automated challenge review's ha… fim-int-2026-07-05-G002: The automated challenge review's hard-flag correction (CoFTRA no longer a crypto sectoral supervisor since January 2025) has not yet been reflected in a re-issued, T1-verified baseline profile record. [resolved] fim-int-2026-07-05-G003: The claim that Indonesia is the onl… fim-int-2026-07-05-G003: The claim that Indonesia is the only Southeast Asian jurisdiction with a central beneficial-ownership registry lacks a comparative regional verification source. [resolved] fim-int-2026-07-05-G004: The June 2026 FATF follow-up report… fim-int-2026-07-05-G004: The June 2026 FATF follow-up report re-rating Recommendation 6 was not reflected in the baseline profile's fatf_status/regulatory_framework_summary narrative fields, creating an internal inconsistency requiring a refreshed profile synthesis pass. [resolved] fim-int-2026-07-05-G005: The PT Timah asset-recovery enforce… fim-int-2026-07-05-G005: The PT Timah asset-recovery enforcement action relies on a T2 Bloomberg source when a T1 Indonesian state-news (ANTARA) source directly confirming the same event is available; re-sourcing to the T1 primary would strengthen corroboration. [resolved] fim-int-2026-08-05-G001: Primary MOL Regulation 2/2025 text … fim-int-2026-08-05-G001: Primary MOL Regulation 2/2025 text not retrieved; BO-verification reform claims rest on a single T4 legal-commentary source. [resolved] fim-int-2026-08-05-G002: Refreshed Indonesian National Risk … fim-int-2026-08-05-G002: Refreshed Indonesian National Risk Assessment (last published 2015) not located; current ML/TF/PF threat-profile calibration cannot be independently verified this cycle. [resolved] fim-int-2026-08-05-G003: FATF's reported June 2026 third enh… fim-int-2026-08-05-G003: FATF's reported June 2026 third enhanced follow-up upgrade for Indonesia is single-sourced (T4) and not verified against the primary FATF publication. [resolved] fim-int-2026-08-05-G004: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-08-05-G004: Tier D jurisdictions (KH, LA, MX, CO) were not independently swept this cycle beyond an incidental, unconfirmed Cambodia-Indonesia relocation signal. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No T1 primary-regulator publication of the MOL Regulation 2/2025 text was directly reached this cycle; confidence capped at Assessed. [resolved] fim-int-2026-09-05-G002: D3 (enabler jurisdictions), D4 (con… fim-int-2026-09-05-G002: D3 (enabler jurisdictions), D4 (conflict finance), D6 (compliance technology) substantive Indonesia findings were not reached this cycle. [resolved] fim-int-2026-09-05-G003: No enforcement_actions[] or sanctio… fim-int-2026-09-05-G003: No enforcement_actions[] or sanctions_changes[] direct source URL was located for Indonesia this cycle. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 primary text of P2SK Law 4/2026 task-force instrument retrieved this cycle; reliance is on secondary press reporting. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): PPATK's own primary statistical release for the IDR286.84 trillion 2025 figure was not directly retrieved this cycle. [resolved] fim-int-2026-09-28-G003: No dedicated Tier D (KH/LA/MX/CO) q… fim-int-2026-09-28-G003: No dedicated Tier D (KH/LA/MX/CO) queries were run this cycle; Tier D coverage is a gap, not a finding of no material change. [resolved] fim-int-2026-10-04-G001: No dedicated Tier D (KH/LA/MX/CO) s… fim-int-2026-10-04-G001: No dedicated Tier D (KH/LA/MX/CO) search was run this pass beyond the Indonesia-bound scope of this dispatch. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 Sanctions, D2 Beneficial Ownership, D3 Enabler Jurisdictions, D4 Conflict Finance, and D6 Compliance Technology carried no Indonesia-specific material finding this cycle; thin coverage recorded. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): PPATK's QRIS deposit figures and account-suspension totals rest on a single T1 self-reported FIU press release with no independent corroboration or raw dataset retrieved this cycle. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No OJK primary circular/POJK/SEOJK number was located to confirm the NIK-based bank screening directive reported 2026-10-07. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Primary Permenkum 2/2025 text was not retrieved this cycle to confirm article-level detail of the UBO re-verification requirement. [resolved] fim-int-2026-10-11-G003: D1, D3, D4, D6 had thin or no cover… fim-int-2026-10-11-G003: D1, D3, D4, D6 had thin or no coverage this cycle; no Indonesia-specific finding located in those domains. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Indonesia-specific Russian sanctions-evasion architecture nexus found; D4 conflict-finance coverage thin this cycle. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (beneficial ownership), D3 (enabler jurisdictions), D4 (conflict finance) and D6 (compliance technology) produced no qualifying Indonesia-specific finding this cycle. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No T1 OJK/PPATK primary notice retrieved for the bank-account disruption campaign this cycle; capping confidence at Probable. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): No newly-dated AML-specific implementing circular for crypto-asset supervisory transition located inside the current window. [open] fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No OJK or PPATK primary-domain document was directly reached this cycle; the account-freeze and turnover figures rest on press relay of an official press conference. [open] fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): FATF's own primary follow-up report document was not directly reached this cycle; the compliance-rating breakdown rests on a secondary-source whitepaper. [open] FIM-GAP-001 (D2): Despite Indonesia's central beneficial-own… FIM-GAP-001 (D2): Despite Indonesia's central beneficial-ownership registry (the only one of its kind in Southeast Asia), fewer than 30% of registered corporations have complied with mandatory BO reporting, and submitted data is not independently verified by the registry authority. FIM-GAP-002 (D4): Money-laundering investigations tied to en… FIM-GAP-002 (D4): Money-laundering investigations tied to environmental and forestry crime remain low relative to the substantial proceeds these crimes generate, despite Indonesia's Ministry of Environment and Forestry recently gaining mandate to investigate related money laundering. FIM-GAP-003 (D3): DNFBP supervisors (notaries, lawyers, real… FIM-GAP-003 (D3): DNFBP supervisors (notaries, lawyers, real estate agents, dealers in precious metals/stones) have less-developed AML/CFT supervisory systems than OJK/Bank Indonesia, and remedial action for breaches is overwhelmingly limited to warnings rather than licence-level sanctions. FIM-GAP-004 (D6): This baseline's evidentiary base for Indon… FIM-GAP-004 (D6): This baseline's evidentiary base for Indonesia relies heavily on FATF, UNODC and international investigative/vendor reporting in English; direct Bahasa Indonesia-language primary publications from PPATK, OJK and Bank Indonesia (e.g. PPATK annual reports, OJK circular letters) were not independently retrieved in this research pass. ## Evidence #### Confidence-tiered claims QRIS-based deposits reached IDR 12.36 trillion (56.04% of total online-gambling deposit value, 198.77 million transactions) in H1 2026 [[Source 1]](#sec-sources) Probable · 1 source 2,815 accounts holding IDR 325.43 billion suspended linked to World-Cup-period gambling activity [[Source 1]](#sec-sources) Probable · 1 source 3rd Enhanced Follow-up Report and Technical Compliance Re-Rating published by FATF, June 2026 [[Source 1]](#sec-sources) Probable · 1 source 4.1 million gambling-content items blocked between 20 October 2024 and 28 September 2026 [[Source 1]](#sec-sources) Probable · 1 source OJK holds full crypto-asset AML/CFT supervisory authority under the amended P2SK Law, effective 17 June 2026 Uncertain Banks ordered to use national identity numbers (NIK) to identify and block accounts, beyond those already flagged, suspected of channelling illegal online-gambling funds [[Source 1]](#sec-sources) Probable · 1 source Regulation No. 2 of 2025 introduced mandatory annual re-verification and a 3-working-day update window for UBO ownership/control changes under Presidential Regulation 13/2018 [[Source 1]](#sec-sources) Probable · 1 source June 2026 plenary added Bosnia-Herzegovina and Iraq to the grey list; delisted Algeria and Namibia; Indonesia's own status unaffected [[Source 1]](#sec-sources) Probable · 1 source PT Enkripsi Teknologi Handal (NOBI), rebranded Bybit Indonesia [[Source 1]](#sec-sources) Probable · 1 source PT Buana Capital Sekuritas and PT Pedagang Aset Kripto, subject to OJK approval [[Source 1]](#sec-sources) Probable · 1 source FATF's June 2026 3rd Enhanced Follow-up Report upgraded Indonesia's TFS criteria, crediting PPATK Decree 670 [[Source 1]](#sec-sources) Probable · 1 source Danantara Monitor alleges Article 50A weakens AML due diligence; PPATK disputes this characterisation [[Source 1]](#sec-sources) Disputed · 1 source 2026 Financial Services Omnibus Law gives OJK freeze/block power over non-compliant crypto activity, including foreign operators with no local presence; criminalises unlicensed crypto-asset business [[Source 1]](#sec-sources) Probable · 1 source OJK ordered banks to use NIK to trace accounts linked to gambling; EDD or block applied to 38,796 accounts; PPATK suspended 5,762 operator accounts [[Source 1]](#sec-sources) Probable · 1 source Law No. 8 of 2010, GR 74/2015, POJK 8/2023; supervised by Bank Indonesia, OJK and PPATK; FATF member since Oct 2023, not grey-listed [[Source 1]](#sec-sources) Probable · 1 source Compliant [[Source 1]](#sec-sources) Probable · 1 source 38796 [[Source 1]](#sec-sources) Probable · 1 source completed [[Source 1]](#sec-sources) Probable · 1 source Compliant (upgraded from Partially Compliant, 3rd Enhanced Follow-up Report, June 2026) [[Source 1]](#sec-sources) Probable · 1 source 38796 [[Source 1]](#sec-sources) Probable · 1 source Crypto-asset service providers moved from Bappebti (commodity regime) to OJK (financial-institution AML/CFT regime) via Law No. 4 of 2026 amending the P2SK Law, effective 17 June 2026 [[Source 1]](#sec-sources) Probable · 1 source Multi-agency push to sever payment pathways for illegal online gambling; OJK reported instructing banks to EDD-check and block 39,923 accounts, up 1,127 since early October 2026 [[Source 1]](#sec-sources) Probable · 1 source Full FATF member since 27 Oct 2023 (40th member); not on any increased-monitoring list; June 2026 3rd Enhanced Follow-up Report rated 7 compliant / 30 largely compliant / 3 partially compliant of 40 Recommendations, with a Recommendation 6 upgrade credited to a December 2025 PPATK decree [[Source 1]](#sec-sources) Probable · 1 source