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133 1. Data collection
In the process of identifying money laundering offences threat factors in the period of 2015 to 2018, the NRA Team of Indonesia has collected data/information from various stakeholders of the Anti Money Laundering and Countering the Financing of Terrorism regime. The data collection activity was carried out through statistical data, the 2015 NRA study, review of the results of risk assessment in the period of 2015 - 2018, interviews, or Focus Group Discussions. The results of the studies which became our literatures including:
The 2015 NRA
The Results of Indonesia Mutual Evaluation Report 2018
The SRA during the period of 2015 – 2018
Other Strategic Research during the period of 2015 – 2018
Mitigation measures that have been carried out in the period of 2015 – 2018
Mitigation measures to be carried out in the period of 2019 – 2010 2. Preparation Stage
a. Kick off Meeting
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The kick off meeting was held on March 20-23 2019 in Bogor and at the same time the initial phase of the FGD with Law Enforcement Officers, Regulators and Other Parties, as a follow-up to the NRA Working Group Discussion held in Bandung on February 14-16 2019.
As a focal point/national organizer, the NRA team of the Indonesian FInancial Transaction Reports and Analysis Center has sent a notification letter and introduction letter to any and all regulators, law enforcement officers, and any other relevant parties on March 19, 2019.
This was intended as a notification to any and all leadership of relevant agencies as Leading Sector that the Indonesian Financial Transaction Reports and Analysis Center will need support from thoses agencies respectively.
The documentation of NRA Update kick off meeting and FGD with law enforcement officers, regulators and other relevant parties are belows.
Bogor, March 20 – 23, 2019
b. Strengthening Commitments of Regulators (FSA)
As a form of commitment of the Head of the Financial Services Authority to the NRA Program, in April 2019 the Financial Services Authority had conducted intensive coordination with INTRAC, and also another meeting was organized by the Financial Services Authority in Jakarta on April 4, 2019.
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c. Organization of NRA FGD for Law Enforcement Officers, Regulators, other Relevant Parties
The second stage of FGD was held in Bandung on May 1-4, 2019.
The third stage of FGD was held in Bandung on May 9-11, 2019.
d. FGD on PESTEL of money laundering offences analysis in Indonesia and FGD of Finalizing of the Draft of NRA Update Report
This FGD was conducted with PESTEL experts (Political, Economic, Social, Technology and Environment and Legal) to provide views to enrich the conclusions and recommendations generated in this studies
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on which attended by all stakeholders and other relevant parties in order to finalize the Draft of NRA Update Report.
The FGD was held in Jakarta, May 20-22, 2019 a) Inspector General (Pol.) Benny Mamoto
b) Mr. Deni R. Tama
c) Dr. Yunus Husein, S.H., LL.M
137 d) Mr. Kuseryansyah
138 Appendix B: PESTEL Analysis
PESTEL analysis is intended to obtain a broad view of the results of the analysis conducted by the stakeholders. The PESTEL experts involved at the stage are experts in the fields of Politics, Economy, Social, Technology and Environment and Legal who delivered their insights to enrich the conclusions and recommendations generated herein.
Some points of PESTEL's findings include:
NO FIELD ASPECTS EXPERT VIEW
1 Political, Economic and Legal
Domestic Risk
High risk domestic predicate offences:
Narcotics crime, corruption crime and banking crime, among others because Indonesia is a potential narcotics market, criminal corruption statistics are still very high and there are many banking crimes, especially fake investments and illegal banks.
Corruption crime Foreign
Risk
Narcotics and corruption crimes were criminal acts having the potential of foreign risk of money laundering offences, among others due to the large number of narcotics smuggling and the availability of facilities abroad to create companies
Mitigation In the context of preventing and eradicating money laundering crimes, the following measures are needed:
a. Institutional strengthening and improvement of investigators and analyst competencies.
b. Improvement of prevention systems, data and information integration
c. Increasing domestic and foreign cooperation.
d. Conduct of law enforcement with multidoor approach, in this case the imposition of a combination of laws in eradicating money laundering crimes
2. Technology Mitigation Mitigation measures in the context of preventing and eradicating money laundering offences:
a. Information integration
b. Issuance of guidelines on anti money laundering and countering the financing of terrorism for fintech
139 Appendix C: References
Asia/Pacific Group on Money Laundering (APG), 2018. Anti Money Laundering and Counter-Terrorist Financing Measures Indonesia Mutual Evaluation Report.
National Narcotics Board, National Police, and Indonesian Financial Transaction Reports and Analysis Center, 2017. Risk Assessment of Money Laundering in Narcotics Crimes.
Commodity Futures Trading Supervisory Board and Indonesian Financial Transaction Reports and Analysis Center, 2017. Money Laundering and Terorrist Financing Risk Assessment in the Sector of Commodity Futures Trading.
Bank Indonesia and the Indonesian Financial Transaction Reports and Analysis Center, 2017. Risk Analysis of Money Laundering and Terrorism Financing in Non-Bank Foreign Exchange Business Sector (KUPVA BB) and Remittance Operator.
Directorate General of General Law Administration of Ministry of Law and Human Rights and the Indonesian Financial Transaction Reports and Analysis Center, 2018. Risk Assessment of Money laundering offences in Notary Sector.
Directorate General of Customs and Excise of Ministry of Finance and Indonesian Financial Transaction Reports and Analysis Center, 2017. Risk Assessment of Money Laundering and Financing Terrorism in Customs and Excise Sector.
Directorate General of Tax of Ministry of Finance and Indonesian Financial Transaction Reports and Analysis Center, 2017. Indonesia Money Laundering Risk Assessment on Tax Crimes.
Directorate General of Tax of Ministry of Finance, 2017. White Papers Update Vulnerabilities of Risk Mapping of Indonesia against Money Laundering Offences in Taxation Sector.
Directorate General of State Assets of Ministry of Finance, 2017. Sectoral Risk Assessment of Money Laundering Offences in Auction Hall.
Ministry of Cooperatives and Small and Medium Enterprises and Indonesian Financial Transactions Reports and Analysis Center, 2018. Sectoral Risk Assessment of Cooperatives Conducting Savings and Loans against of Money Laundering Offence and Countering the Financing of Terrorism.