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Edunity
Volume 2 Number 9, September, 2023
p- ISSN 2963-3648- e-ISSN 2964-8653
Doi:
https://edunity.publikasikupublisher.com/index.php/Edunity/index
JURIDICAL REVIEW OF THE ROLE OF NOTARIES IN THE
IMPLEMENTATION OF ANTI MONEY LAUNDERING
PROGRAMS
Muhammad Yusli Juliansyah
1*
, Benny Djaja
2
Universitas Tarumanegara, Jakarta, Indonesia
Email: yus[email protected]
1*
, [email protected]
2
ABSTRACT
Abstract: The Notary profession is always guided by the prevailing laws and regulations
including Law Number 30 of 2004 as amended by Law Number 2 of 2014 concerning Notary
Positions. This study aims to illustrate the role of Notaries in the implementation of anti-money
laundering programs as stipulated in Government Regulation Number 43 of 2015 concerning
Reporting Parties in the Prevention and Delivery of Anti-Money Laundering Crimes submitted
to the Center for Financial Transaction Reporting and Analysis (PPATK). Based on this
description, this study uses the Normative Juridical research method
Keywords: TPPU; Notary; Money Laundering; Implementation of Anti-Money Laundering
Program; Center for Financial Transaction Reporting and Analysis
Introduction
The law will never be separated from human life. If man and the law continue to grow
and interrelate with each other, then talking about the law is inseparable from talking
about it from human life (Mertokusumo, 1999). Indonesia's economic development is
not always followed or in line with legal developments, in order to support the growth
rate of Indonesia's economic institutions. This situation occurs because of the lack of care,
between the development of economic institutions and legal reform (Sjahdeini, 1983).
The growth rate of financial transactions and the ease of applying technology to facilitate
the process of financial transactions have an impact on new legal problems. The
continued growth of economic activities causes activities and relationships between
humans to become massive and develop. In everyday life, the more often it is inter-legal
subjects, the greater the potential for conflict or the greater the opportunity for legal
problems to arise in the midst of people's lives (Metakusumo, 1996).
Money Laundering is any act that meets the elements of a criminal act in accordance
with the provisions in the PPTPPU Law. Money laundering is carried out by certain
individuals to avoid their obligations, such as running away from tax obligations or
other legal obligations. Money laundering is a crime that covers a wide scope and its
scope extends beyond national and international territories. Starting in the 1920s,
organized crime perpetrators in the United States, laundered money from psychotropic
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substances through laundry businesses. The perpetrators set up a laundry business as a
hiding place for illicit money (Suleaman, 2018). Developing from this, the perpetrators
of money laundering crimes carry out violations of the law with various variants,
including within the scope of the Notary profession.
In carrying out their work, Notaries are required to guide Law No. 30 of 2004 as
amended by Law No. 2 of 2014 concerning Notary Positions or can be referred to as
UUJN. The Notary profession has existed since the Dutch colonial rule, which at first the
existence of Notaries was a necessity for Europeans residing in Indonesia in creating
authentic evidence of land ownership which until now has become perfect evidence of
land ownership or other objects codified with authentic deeds. The existence of a notary
is increasingly needed in making authentic written evidence of a legal act carried out by
the community. Some laws and regulations require certain legal acts to be made in
authentic deeds. Notaries and their deed products can be interpreted as state efforts to
create legal certainty and protection for members of the public (Setiyawan, 2020). Money
laundering is the act of altering and hiding cash or assets obtained from a crime, which
appear to come from legitimate sources. The problem of money laundering began to be
discussed because it occupied a lot of national and international attention due to the
dimensions and implications that violate national borders. As one of the crime
phenomena that mainly concerns the world of "organized crime", it turns out that there
are certain parties who enjoy the benefits of money laundering without realizing the
impact of the losses caused (Tetehuka, 2019).
As a party who knows legal acts, Notaries are very vulnerable to potential violations and
abuse of authority, one of which is money laundering. In professionalism, legal
practitioners are known as gatekeepers in money laundering. The term gatekeeper is
agreed with financial and legal professionals with expertise, knowledge, and special
access to the global financial system that utilizes expertise to conceal the proceeds of
money laundering crimes that have been committed (Yoga & Valentina, 2022). With their
expertise and knowledge, notaries can participate in hiding money laundering crimes.
Along with the times and the pace of the economy, various kinds of financial
transactions have also developed and increased, various business transactions involving
Notaries are also increasingly varied, this is due to the needs of business people or
interested parties for authentic written evidence (Dhaneswara, 2020). However, not all
parties who come to the Notary Public are to carry out a clean transaction, there are also
parties who come in bad faith with the aim of carrying out a financial transaction that
actually violates the law with the aim of getting protection behind the confidentiality
provisions of the Nitarist profession as regulated by the provisions of laws and
regulations so that the transactions carried out seem clean. One form of such crime is
money laundering.
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It can be concluded that, money laundering can be interpreted as the act of converting
money from criminal acts into clean money as if obtained through halal work. There is
one feature that can be done against money launderers by transferring illegal assets into
the economic system. As explained, the transfer of illegal assets that can be carried out
by perpetrators of laundering crimes usually involves a notary to transfer illegal assets
obtained from the money laundering crime. Therefore, based on Government
Regulation No. 43 of 2015 concerning the Reporting Party in the Prevention and
Eradication of Money Laundering with the existence of PP 43/2015 interprets that Notary
is one of the professions that plays a major role in the disclosure of money laundering
crimes.
In connection with the explanation above regarding related to the risk to the Notary
profession against the rise of money laundering crimes, the author assumes to research
further about "Juridical Review of the Role of Notaries in the Implementation of Anti-
Money Laundering Implementation". With the formulation of the problem, the focus of
the author is:
1. How Important is the Role of Notaries in the Implementation of Money Laundering
Implementation Programs? and
2. What Will Be the Impact If the Notary's Role in the Implementation of Money
Laundering Programs Does Not Work Well?
Research Method
This research uses the Normatid Juridical method that explains the science of law, using
an approach carried out with library research using literacy of Laws and Regulations
and books or articles related to the topic in this study. This research is Descriptive
Analytical which aims to describe or describe an object under study through data or
samples that have been collected as they are without conducting analysis to make
conclusions that apply to the public.
Result and Discussion
Notary Function in the Implementation of Anti-Money Laundering Program
A Notary in carrying out his profession to provide services to the community should
behave in accordance with applicable laws and regulations. The Notary Department is
a trust position that must be in harmony with those who carry out the duties and
positions of the notary as a trusted person. Notaries as a position of trust do not mean
anything if it turns out that they carry out the duties of the office as a notary are people
who cannot be trusted. In this case, the notary office and its officials (who carry out the
duties of the notary office) must be in line like two sides of a coin that cannot be
separated (Edwar et al., 2019).
Deep carrying out his duties and position a Notary must be guided by the code of ethics
for the position of Notary, if not applied in a Notary, it will cause the dignity and dignity
of professionalism of a Notary to be lost and can result in matters related to criminal
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acts. Therefore, a Notary Public is obliged to have integrity in carrying out his profession
so as not to be involved in matters that harm the Notary profession.
In the realm of the Application of Money Laundering, the Notary Profession is
vulnerable to being used by perpetrators of money laundering crimes because of the
confidentiality provisions provided under the Notary Position Law. Based on Law
Number 8 of 2010 concerning the Prevention and Eradication of Money Laundering by
explaining acts that become money laundering, as follows:
1. Place, transfer, transfer, spend, pay, grant, deposit, carry abroad, change form,
exchange, for currency or securities or other acts of property that he knows or
reasonably suspects are the proceeds of a criminal offense with the aim of concealing
or disguising the origin of the property; (Viki, 2020)
2. Conceal or disguise the true origin of the source, location, designation, transfer of
rights, or ownership of property that he knows or reasonably suspects is the
proceeds of a criminal offense; (Manopo, 2022)
3. Receiving, controlling the placement, transfer, payment, grant, donation, custody,
exchange, or use of property that he knows or reasonably suspects is the proceeds
of a criminal offense (Amalia, 2016).
These actions, the impact on notaries if notaries do not have integrity will have an impact
on criminal risks. Based on this, the government issued Regulation of the Minister of
Law and Human Rights Number 9 of 2017 concerning the Application of the Principle
of Recognizing Service Users for Notaries by stipulating additional duties that must be
carried out by Notaries. The addition of Notary duties must be carried out by applying
the principle of recognizing Service Users. These principles contain at least, among
others: (Simbolon & Sinaga, 2023)
1. Identification of Service Users;
2. Service User Verification;
3. Monitoring of Service User Transactions.
Since the enactment of the regulation on the principle of recognizing service users for
Notaries, Notaries are obliged to be able to deal with service users who deal with them
by being given tools of principles that can be upheld by Notaries. Notaries are obliged
to use the principle of recognizing service users regarding several things, including
(Adjie, 2020):
1. Property Transactions;
2. Management of Money or Assets;
3. Company Management; and/or
4. Legal Entity Transactions.
The obligation to apply the principle of recognizing service users is carried out when: a)
Notaries have relationships with service users; b) at the time of the occurrence of a
Financial Transaction whose value is at least or equivalent to Rp. 100,000,000.00 (one
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hundred also rupiah); c) Financial Transactions are suspected of being related to
terrorism financing crimes, and d) the notary doubts the veracity of the information
reported by the service user (Putri & Rahayu, 2023).
Not only applying the principle of recognizing service users, Notaries must also
recognize Beneficial Owners. Beneficial Owner or beneficial ownership is a term in the
world of commercial law that refers to who enjoys the benefits of ownership of certain
assets without being recorded as an owner. Many people want to protect their assets. by
using trusts to act as legal owners of assets, while they become beneficial owners.
(Hamsah, 2021)
The introduction of Beneficial Owners is also important in the application of money
laundering programs by Notaries. Usually, money launderers protect their assets by
using trusts to act as the legal owners of assets, while they become beneficial owners.
This counterfeiting is generally legal for everyone but should be regulated because it can
be abused and is very close to criminality. Money laundering does not use corporations
to conceal their identity regarding the origin and use of funds or assets sourced from
criminal acts.
Based on the Regulation of the Ministry of Law and Human Rights of the Republic of
Indonesia Number 9 of 2017 concerning Recognizing Service Users for Notaries, what is
meant by Beneficial Owner is: (Prayitno, 2017)
1. Any Person who has money and/or receives certain benefits for a transaction which
is directly or indirectly;
2. Any Person who is the actual owner of a transaction;
3. Any Person who controls a transaction;
4. Any Person who authorizes a transaction;
5. Any Person who controls the Corporation; and/or
6. Any Person who is the ultimate controller of a transaction.
Notaries are public officials who have been trusted by the government so they are given
authority. The trust given by the government should always be maintained by a Notary
Public maintaining the trust that has been given by the government. Noatrist in
maintaining this trust in a way that cannot be controlled by the client which results in
prioritizing the client rather than enforcing the rules that have been applied. (Adjie, 2020)
For this reason, Notaries have the necessary role and function in preventing money
laundering by reporting to the Financial Transaction Reporting and Analysis Center
(PPATK) when they know of suspicious transactions related to the deeds they make. In
the face of money laundering crimes, such professionals as notaries are obliged to report
suspicious transactions on behalf of or for clients. Notaries who conduct business
relations must understand the profile, purpose, and purpose of business relations. In
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addition, transactions made by service users and beneficial owners for identification and
verification.
Notary's Obligation in Following the Development of Information Technology
Indonesia initiated regulations regarding money laundering with Law Number 15 of
2002 concerning Money Laundering, promulgated on April 17, 2022. The year 2003 was
amended by Law Number 25 of 2003 concerning Amendments to Law Number 15 of
2002 concerning the Crime of Money Laundering, promulgated on October 13, 2003. The
changes, which are only 18 (eighteen) months, are carried out in order to prevent and
run effectively, meeting law enforcement standards related to money laundering, in
accordance with the development of information technology and the development of
criminal law on money laundering and international standards (Rudy Haposan Siahaan,
Rini Irianti Sundary, 2022).
Technological progress is something that cannot be avoided in this life, because
technological progress will go according to the progress of science. Every innovation is
created to provide positive benefits for human life. Technology also provides many
conveniences, as well as a new way of doing human activities. Humans have also
enjoyed many benefits brought by technological innovations that have been produced
in the last decade. (Waqfin et al., 2021)
Hague Convention Abolishing the Requirement of Legalization for Foreign Public
Documents 1961 directs every authorized and competent public authority including
Notaries to simplify and authenticate public documents. This Convention encourages
the emergence of 2 (two) important concepts, especially related to the role of Notaries in
realizing the effectiveness of electronic transactions, namely Cyber Notary and
Electronic Notary. Cyber Notary was initiated as an idea of the American Bar
Association Information Security Committee. Cyber Notary has many implementations
in common law countries such as the United Kingdom, the United States, Canada, and
Australia. (Nasution, 2011) So that in carrying out their work, Notaries can be helped to
report to PPATK clients who are indicated to have made Suspicious Financial
Transactions.
Notary Public as the Reporting Party of Suspicious Financial Transactions
In the Anti-Money Laundering Regime, the reporting party is a front liner who has a
strategic role in detecting suspicious financial transactions or reporting certain
transactions in accordance with the provisions of Law No. 8 of 2010 concerning the
Prevention and Eradication of Money Laundering (PPTPPU Law). Based on the PPTPPU
Law, in addition to obligations, there is also special protection for reporting parties. The
obligation to identify financial transactions and report by the whistleblower is also part
of the application of prudential principles and part of risk management, to prevent the
use of CHDs / PBJ as a means or target of money laundering by customers/service users.
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In this case, avoid CHD and BJP against reputational risk, operational risk, legal risk,
and concentration risk. (Comyns, 2016)
Based on Government Regulation Number 43 of 2015 concerning the Reporting Party in
the Prevention and Eradication of Money Laundering which states Notaries are one of
the professions that become reporting parties as Notaries are required to apply the
principle of recognizing service users with stages determined by laws and regulations.
Therefore, as a Notary, it is mandatory to keep up with the times so that it can help him
to carry out his profession properly and correctly.
The report that must be reported by a Notary to the Financial Transaction Analysis and
Reporting Center (PPATK) is a Suspicious Financial Transaction Report which includes:
a. Financial Transactions that deviate from the profile, characteristics, or habits of the
Transaction pattern of the Service User concerned;
b. Financial Transactions by Service Users that are reasonably suspected to be carried
out with the aim of avoiding reporting the relevant Transactions that must be carried
out by the reporting party in accordance with the provisions of laws and regulations
governing the prevention and eradication of money laundering;
c. Financial Transactions carried out or canceled using Assets allegedly derived from
the proceeds of criminal acts; or
d. Financial Transactions requested by the Center for Financial Transaction Reporting
and Analysis to be reported by the reporting party because they involve Assets
allegedly derived from the proceeds of criminal acts. (Manalu, 2021)
Based on the Regulation of the Head of the Center for Financial Transaction Reporting
and Analysis Number 11 of 2016 concerning Procedures for Submitting Suspicious
Financial Transaction Reports for the Profession, in carrying out reporting to PPATK
Notaries are required to assign reporting officers, register through the GRIPS
application, and report to PPATK.
The format of the report carried out by the Notary Public must meet the criteria required
by PPATK. Not only the reporting format has been determined, but Notaries are
required to fill out the Suspicious Financial Transaction report correctly and completely
in accordance with the instructions for filling out the Suspicious Financial Witness report
determined by PPATK. If the Notary does not perform properly and correctly, it will
result in the Notary being subject to administrative sanctions by the PPAT. Filling out
the Suspicious Financial Transaction Report is done through the GRIPS application.
Filling out the Suspicious Financial Transaction report is carried out by a notary officer
by manually filling in the suspicious financial transaction report on the GRIPS
application or uploading files to the GRIPS application in Microsoft Exel format.
Notaries are obliged to submit Suspicious Financial Transaction Reports electronically
by sending reports through the GRIPS application to telecommunication networks
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addressed directly to the PPATK database, through a web-based application provided
by PPATK.
The period for submitting a Suspicious Financial Transaction report must be submitted
by a notary as soon as possible no later than 3 (three) working days after the Notary
becomes aware of any elements of Suspicious Financial Transactions. The period of 3
(three) working days is calculated from the date the Transaction is made until the
delivery date recorded automatically in the GRIPS application for electronic delivery.
Notaries can make reporting corrections in the event that the Notary finds itself errors
in the Suspicious Financial Transaction report that has been submitted to PPATK or the
Notary receives administrative sanctions imposed by PPATK. In the event that the
Notary finds an error in the Suspicious Financial Transaction report that has been
submitted to PPATK, the Notary is obliged to make corrections to the Suspicious
Financial Transaction no later than 3 (three) working days after discovering the error
himself. The application of submission of 3 (three) working days also applies if the
Notary receives administrative sanctions from PPATK.
Notaries are obliged to submit supporting documents for the Suspicious Financial
Transaction report no later than 3 (three) working days after the submission of the
Suspicious Financial Transaction report is submitted to PPATK. Supporting documents
in the form of at least:
a. Identity of users of services, products, and portfolios owned;
b. The results of due diligence on service users;
c. Document evidence of conduct "for the benefit of or for and on behalf of the service
user".
If the documents that have been submitted according to PPATK have not described the
existence of Suspicious Financial Transactions, PPATK is authorized to request
additional documents from the Notary related to the Suspicious Financial Transaction
report. If PPATK requests additional documents to assist in the analysis of Suspicious
Financial Transactions, the Notary is obliged to submit the additional documents no later
than 20 (twenty) working days after the Notary receives a written letter from PPATK
Conclusion
First, the Notary Function of the Anti-Money Laundering Program is very important to
be carried out based on the modes of criminal perpetrators of laundering by hiding their
assets obtained through unlawful acts, because the notarial deed contains a statement
about a situation, event, or legal act desired by the parties to be stated in the notarial
deed as perfect evidence of ownership with the aim of concealing the proceeds of a
criminal act. So, with the existence of these empty gaps with the arrangements related to
the Implementation of Anti-Money Laundering Programs implemented by Notaries, it
is very important to patch these empty gaps.
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Second, the Notary Deed is perfect evidence, so its perfection must be maintained so that
evidence of ownership of rights cannot be tainted with actions resulting from violations
of the law. So, if the implementation of the Anti-Money Laundering Program is not
applied properly to Notaries, it will make it easier for criminal actors to hide their
property by taking refuge with the notarial deed that the Notary made for him.
Therefore, it is important to implement an anti-money laundering program for notaries
in order to maintain the perfection of notarial deeds to be honest evidence, free from
interference from other parties, and not hide the results of criminal acts.
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