Regulatory Update: Strengthening Anti-Money Laundering Coordination and Enforcement under Presidential Regulation No. 88 of 2025
by Setyawati Fitrianggraeni and Tiara Amanda Putri
Overview
Presidential Regulation No. 88 of 2025 was issued to strengthen anti-money laundering efforts by restructuring the National Coordination Committee.(1) This regulation responds to the evolution of economic crimes in Indonesia, which have become increasingly complex, organized, and facilitated by advances in information technology and the globalization of financial systems.(2) This phenomenon requires progressive legal adaptation, as perpetrators of money laundering increasingly exploit corporate structures,(3) banking institutions, and even non-profit organizations (foundations) to carry out the stages of placement, layering, and integration.(2)
This regulation aims to address these gaps by prioritizing a follow-the-money strategy to detect suspicious financial transactions and ensure more effective recovery of state assets.(2) It also strengthens national governance by addressing risks in vulnerable sectors, including Regional-Owned Enterprises(4) and philanthropic foundations, which are often misused to conceal funds or facilitate terrorism financing through anonymous donations.(5)
Key Highlights
- Restructuring of the National Coordination Committee for Anti-Money Laundering (AML)
The government restructures the membership of the National Coordination Committee for the Prevention and Eradication of Money Laundering or Komite Koordinasi Nasional Pencegahan dan Pemberantasan Tindak Pidana Pencucian Uang (Komite TPPU) to strengthen oversight and enforcement. The Committee is chaired by the coordinating minister for Law, Human Rights, Immigration, and Corrections, with the Coordinating Minister for Economic Affairs as Vice Chair and the Head of Indonesian Financial Transaction Reports and Analysis Centre or Pusat Pelaporan dan Analisis Transaksi Keuangan (PPATK) as Secretary and member, involving 18 ministries and institutions including the Attorney General, the Chief of Police, and the Head of the National Narcotics Agency. This restructuring is carried out through the amendment of Article 5 of Presidential Regulation No. 6 of 2012 to enhance inter-agency coordination in addressing money laundering across sectors.(1)
- Standardization of Working Mechanisms and Operational Guidelines
The regulation introduces a new provision requiring formal operational guidelines for the activities of the Committee and its supporting units to ensure legal certainty and administrative order. These guidelines are established by the Chair of Komite TPPU and apply to the Implementing Team, expert groups, and ad hoc working groups formed for specific cases. This measure is implemented through the insertion of Article 13A between Articles 13 and 14 to standardize procedures for reporting, transaction analysis, asset tracing, and international mutual assistance.(1)
- Operational Synergy Between Intelligence and Law Enforcement
The regulation strengthens the integration of intelligence and counterterrorism functions within the anti-money laundering framework to enhance responses to crimes threatening national security. It involves key institutions such as the State Intelligence Agency or Badan Intelijen Negara (BIN), the National Counterterrorism Agency or Badan Nasional Penanggulangan Terorisme (BNPT), and the Special Detachment 88 of the Indonesian National Police as members of the Implementing Team. Operational coordination is led by the Head of PPATK by integrating suspicious financial transaction data with intelligence and counterterrorism efforts to support asset tracing and accelerate responses to terrorism financing and other transnational crimes.
References
1. Presidential Regulation of the Republic of Indonesia No. 88 of 2025 on the Second Amendment to Presidential Regulation No. 6 of 2012 concerning the National Coordination Committee for the Prevention and Eradication of Money Laundering.
2. Rahma I. Urgensi Peran Pusat Pelaporan dan Analisis Transaksi Keuangan dalam Penegakan Hukum Tindak Pidana Pencucian Uang. Jurnal Hukum Samudra Keadilan. 2022 Oct 2;17(2):193–204.
3. Apriany Marwan W. Pertanggungjawaban Pidana Korporasi dalam Tindak Pidana Pencucian Uang di Indonesia: Penguatan Kerangka Normatif dan Penegakan Hukum. Sawerigading Law Journal. 2024 Mar 24;3(1).
4. Lestari FK. Kolaborasi Bank, PPATK dan OJK dalam Pencegahan Tindak Pidana Pencucian Uang di Indonesia. Lex LATA: Jurnal Ilmiah Ilmu Hukum. 2025 Jul 21;7(2):64–78.
5. Sirait NN, Rangkuti LHY. Non-Profit Organisations (NPOs) as Media for Money Laundering Crimes. AML/CFT Journal: The Journal of Anti Money Laundering and Countering the Financing of Terrorism. 2023 Jun 14;1(2):132–45.
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