Indonesia AML Obligations for Accountants: Law 8 of 2010, PP 43/2015 and PPATK

In Indonesia, accountants and public accountants are named as reporting parties under anti-money laundering (AML) rules made under Law No. 8 of 2010 on the Prevention and Eradication of Money Laundering. The financial intelligence unit, PPATK (Pusat Pelaporan dan Analisis Transaksi Keuangan), receives their reports. This guide sets out what the primary texts say, including Government Regulation No. 43 of 2015 and PPATK Regulation No. 3 of 2021, and lists what we could not confirm. It is general information, not legal advice, and our reading of the Indonesian-language texts is ours.

How accountants became reporting parties

Article 17(1) of Law No. 8 of 2010, in the official English translation, lists financial service providers and a short list of goods and services providers, such as property companies and agents, motor vehicle traders, dealers in diamonds, jewellery and gold, art and antique traders, and auction houses. It does not list accountants. Article 17(2) says other reporting parties are set by Government Regulation. Government Regulation No. 43 of 2015, enacted and promulgated on 23 June 2015, did that. Its article 3 adds advocates, notaries, land deed officials, accountants, public accountants and financial planners to the reporting parties.

What triggers reporting

Article 8(1) of the Regulation says these professions must submit a suspicious financial transaction report to PPATK when they act for or on behalf of a service user in the following activities:

• buying and selling property;
• managing money, securities or other financial service products;
• managing current, savings, deposit or securities accounts;
• operating and managing companies; and
• establishing, buying and selling legal entities.

The Regulation sets no separate activity list for accountants. Article 8(2) exempts advocates when confirming a service user's legal position or handling litigation, arbitration or alternative dispute resolution, and the text we read contains no equivalent exemption for accountants. For the general method of checking who your client is, see our guide to KYC and customer due diligence in accountancy practices.

Registering on goAML and filing

PPATK Regulation No. 3 of 2021, enacted and promulgated on 29 January 2021 and titled on the procedure for submitting suspicious transaction reports through the goAML application for professions, replaces an earlier PPATK head's regulation of 2016. It defines professions to include accountants and public accountants designated as reporting parties, and it covers individuals, individuals within a firm, and corporations. Its main points, as we read them:

• Registration on goAML is mandatory (articles 5 to 23), and existing registrants must update their data.
• Authorised officials must appoint and register an administrator and a reporting officer (article 11).
• Reports are filed electronically through goAML, with paper filing allowed only in listed exceptions such as system failure (articles 29 to 31).
• A suspicious transaction report is due as soon as possible and no later than three working days after the profession becomes aware of its elements (article 28). The Regulation treats awareness as arising on an internal designation, on receipt of a PPATK request, or on signing the minutes of an audit exit meeting.

Other deadlines include three working days to correct errors you identify yourself or errors goAML rejects automatically, and seven working days to re-register after a rejection. Our guide to suspicious activity reports and tipping off is UK-focused but explains the practical sequence of spotting, escalating and reporting.

Record keeping

Article 38(1) of the 2021 PPATK Regulation requires documents on reported customers to be kept for at least five years after the business relationship ends. Article 21(2) of the 2010 Law sets a similar five-year period for identity records and documents, running from the end of the business relationship.

Tipping off and sanctions

Under article 12 of the 2010 Law, as translated, the board, commissioners, management and employees of a reporting party may not tell customers or others that a report is being prepared or submitted. Article 12(5) sets up to five years' imprisonment and a fine of up to Rp 1,000,000,000 for breach. The Law's provisions on failure to report provide administrative sanctions rather than criminal penalties. Under the 2021 PPATK Regulation, violations of the listed provisions may lead to a written warning, a public announcement of the sanction, and an administrative fine, imposed by the relevant supervisory body or by PPATK depending on who supervises the profession. The Regulation text we read does not state fine amounts.

What we could not confirm

• Whether Law No. 8 of 2010 has been amended since the translated version we read, including any changes to penalties.
• Which body supervises accountants and public accountants day to day, and what customer due diligence rules apply to them. We did not read the profession-specific KYC rules.
• The amount of administrative fines for professions.
• Whether an accountant could rely on any exemption beyond the advocate exemption.

Suggested next steps

These are our suggestions, not requirements. Map your services against the five activities in article 8(1). Check whether your firm or you personally are registered on goAML and whether the administrator and reporting officer are named. Write down how staff escalate a suspicion so that a report can be filed within three working days of awareness. For team training, see our CPD courses.

Frequently asked questions

Are accountants in Indonesia reporting parties?

Yes. Government Regulation No. 43 of 2015 names accountants and public accountants as reporting parties, for the activities listed in article 8(1).

How quickly must a suspicious transaction be reported?

As soon as possible and no later than three working days after the profession becomes aware of the elements of a suspicious transaction, under article 28 of PPATK Regulation No. 3 of 2021.

Do accountants have to register on goAML?

Yes. The 2021 PPATK Regulation makes goAML registration mandatory for professions designated as reporting parties.