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ID (ID) · Module W11 · Derived Confidence: Probable

ID: AML/CFT & Financial Crime

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No standing position recorded for this module.

Standing sub-brief · as of 18 October 2026154 words · last cycle 2026-10-18

AML/CFT & Financial Crime

sentinel.fim: OJK ordered banks to use National Identity Numbers (NIK) to trace and act against accounts linked to online gambling, resulting in Enhanced Due Diligence or outright blocking applied to 38,796 accounts. This intelligence is sourced via the Sentinel.gi feed; the underlying illicit-finance analysis of this development belongs to the financial-integrity monitor, and this brief does not re-analyse it. From a payments-infrastructure perspective, the relevant point is that the screening obligation falls on banks as payment-channel participants, meaning affected institutions face an operational requirement to run identity-based cross-account screening at scale against the flagged population.

Outlook

For banks and payment-service providers, the operational question going forward is how the NIK-based screening mechanism is formalised and whether it is extended to other payment-channel participants beyond banks. Readers seeking the underlying illicit-finance analysis of this development should refer to the financial-integrity monitor's coverage, which carries the primary assessment of this Sentinel-sourced finding.

no periodic updates on record for this sub-brief

Coverage Gaps (not_examined model · S-1)3 deficiency record(s) separated from substantive evidence
  • not_examined Gap: sourcing-thinness (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004))
  • not_examined Gap: regulatory-failure (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001))
  • not_examined Gap: capacity-deficit (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003))
Sources and findings (2 unique sources · R-3/R-4)
  1. [W11-E1] T2 Derived: Probable in_forceSentinel (sentinel.gi) per-JID baseline profile — Indonesia re-verified

    Indonesia is a full FATF member (since Oct 2023), governed by AML Law No.8/2010, with PPATK as FIU and OJK/Bank Indonesia/CoFTRA as sectoral supervisors. Crypto oversight transferred from Bappebti/CoFTRA to OJK in Jan 2025 under the P2SK financial-sector law. Follow-up reports (May 2025, June 2026) show steady technical-compliance upgrades, though effectiveness gaps persist in asset recovery, DNFBP supervision, and beneficial-ownership verification.

  2. [W11-E3] T1 Derived: Confirmed in_forceSentinel (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) re-verified

    Enforcement: FATF Plenary — Indonesia's AML/CFT/CPF technical-compliance framework