Anti-Money Laundering Law Regulates Banking Transaction Suspension, Expert Explains Authority
Jakarta – Anti-money laundering expert Yunus Husein has responded to the case involving the suspension of a Bank Mandiri account linked to the fundraising activities of the Aliansi Masyarakat Pati Bersatu (AMPB). Polda Metro Jaya previously explained that the action taken was a transaction suspension for five working days, not a freeze. Police also stated that the transaction would be reopened if no criminal elements were found and the funds in the account had not been reduced.
Yunus said that banks have the authority to suspend transactions or impose a temporary freeze under certain conditions in accordance with Law No. 8/2010 on the Prevention and Eradication of Money Laundering (TPPU). “Banks have their own authority to suspend for five days, but the reasons are limitative,” Yunus said in a statement on Wednesday, 26 August 2026.
He explained that Article 26 of the TPPU Law grants authority to financial service providers, including banks, to suspend transactions for a maximum of five working days under certain conditions. These include when there is a suspicion that assets derived from criminal acts have entered the account or that the account is being used to hold the proceeds of crime.
Yunus said that transaction suspension is the authority of financial service providers under conditions determined by law, whereas actions based on Article 70 of the TPPU Law fall within the context of law enforcement authority. He assessed that transaction suspension in this context should be understood as part of the tracing process, not as a determination that the account holder has committed a criminal offence.
Thus, a transaction suspension carried out by a bank based on its authority under the TPPU Law does not automatically indicate wrongdoing or a criminal offence by the customer. “The determination of whether or not there is a criminal element remains the authority of law enforcement based on the results of an investigation,” he said.
This explanation aligns with the view of the Financial Services Authority (OJK), which stated that transaction suspension has a legal basis and is temporary in nature. OJK said the mechanism is regulated in the TPPU Law as well as Article 47 of POJK No. 8/2023 concerning the Implementation of Anti-Money Laundering, Counter-Terrorism Financing, and Counter-Proliferation Financing of Weapons of Mass Destruction Programmes in the Financial Services Sector.
OJK’s Chief Executive of Banking Supervision, Dian Ediana Rae, said financial service providers may suspend transactions in accordance with statutory provisions. In the context of the Bank Mandiri account linked to AMPB, OJK stated that based on information received so far, the bank’s actions remained in accordance with applicable regulations.