How Danantara Sumberdaya Indonesia Monitors Potential Underinvoicing in Commodity Exports
PT Danantara Sumberdaya Indonesia (DSI) is utilising eight analytical use cases to identify and monitor potential underinvoicing, transfer pricing, and the repatriation of Export Proceeds (DHE) for strategic export commodities.
“To fulfil its mandate, DSI will employ eight analytical use cases to identify and monitor potential underinvoicing, transfer pricing, and DHE repatriation,” stated DSI’s Director of Legal and Compliance, Ivan Ferdiansyah Baely, during a meeting with the Legislative Body of the Indonesian House of Representatives (DPR RI) regarding the Strategic Commodities Bill in Jakarta on Tuesday (15/09/2026).
Ivan explained that the first use case involves quantity reconciliation by comparing the tonnage declared in the Export Declaration (PEB) with surveyor certificates and destination settlements.
Secondly, DSI will perform quality reconciliation, comparing the grades listed in the PEB with surveyor certificates and destination settlements.
Thirdly, Harmonised System (HS) code classification will be conducted by comparing HS codes in the PEB with surveyor certificates and destination results.
Fourthly, DSI will perform price comparisons by matching declared prices against government references. Fifthly, reconciliation with destination countries will be carried out by comparing declared export volumes and values.
Sixthly, DSI will conduct inspections of affiliated parties. Seventhly, route tracking will be performed by comparing declared destinations with actual vessel tracks, buyer payments, and destination settlements.
Eighthly, DHE reconciliation will involve ensuring export proceeds enter the Simodis system in accordance with the values and provisions specified in the PEB.
According to Ivan, the initial phase will cover three strategic commodities: coal, palm oil (CPO), and ferroalloy.
Regarding the execution of this mandate, Ivan emphasised that DSI supports the government and relevant ministries and agencies in determining policy, as DSI serves as an implementer.
Ivan noted that DSI can function as an intermediary or single interface, which includes obtaining data, verifying and analysing transactions, and submitting reports if any concerning indications are discovered.
If discrepancies are found, follow-up actions will remain the responsibility of the relevant authorities holding the appropriate legal powers under existing regulations.
DSI also maintains that the principle of continuity or non-disruption is vital in implementing the new governance for strategic commodities. Business actors with existing trade relationships and ongoing contracts require certainty so that changes in governance do not automatically disrupt existing contracts or export processes.
DSI suggested that the Strategic Commodities Bill should specifically regulate funding sources, objectives, governance, usage, and accountability.
“From DSI’s perspective, if DSI holds a role within the strategic commodity ecosystem, that legal basis and role should be clearly stated in the law, rather than merely through subordinate administrative regulations,” concluded Ivan.