Regulatory Implications of PPATK's Dormant Account Blocking in Indonesia's Banking System: A Legal Analysis

This research aims to analyze the regulatory implications and institutional complexities of dormant account blocking policies implemented by Indonesia's Financial Intelligence Unit (Pusat Pelaporan dan Analisis Transaksi Keuangan - PPATK) within the Indonesian banking system, focusing on regulatory harmonization, institutional coordination, and the balance between anti-money laundering enforcement effectiveness and customers' fundamental rights protection. This study employs a normative juridical method with conceptual and comparative approaches toward international regulatory frameworks. Primary data comprises anti-money laundering legislation, banking regulations, and consumer protection laws. Secondary data was collected through systematic literature studies of 50 academic publications from the 2022-2025 period indexed in Scopus Q1-Q3 and Web of Science, alongside analysis of international regulatory practices, Master’s Thesis and Doctor Philoshopy. Data analysis was conducted qualitatively using legal interpretation techniques and gap analysis between normative provisions and practical implementation. Research findings reveal five primary regulatory problems: (1) absence of firm legal definitions regarding dormant accounts in Indonesia's regulatory framework; (2) authority imbalance between PPATK under Law No. 8 of 2010 and procedural due process principles; (3) coordination disharmony among supervisory institutions (PPATK, Financial Services Authority, and Bank Indonesia) creating regulatory overlap; (4) regulatory impacts on financial inclusion and banking service accessibility; and (5) urgent need for regulatory frameworks integrating financial privacy protection under Law No. 27 of 2022.. This research provides theoretical contributions to banking law dogmatics development regarding balanced regulatory approaches between financial supervision functions and consumer protection. Practically, these findings serve as blueprints for responsive regulatory reform integrating anti-money laundering effectiveness with strengthened procedural safeguards, graduated response system implementation, and development of harmonious institutional coordination mechanisms.

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Publication Details

Journal
Humanities and Social Sciences
Published
2025-10-22
DOI
https://doi.org/10.11648/j.hss.20251305.20
Primary Topic
Legal and Policy Analysis in Indonesia
Type
article
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article

Regulatory Implications of PPATK's Dormant Account Blocking in Indonesia's Banking System: A Legal Analysis

Najib A. Gisymar, Erna Rusmala, Suyikati Rusmala, Anindita Rusmala et al.
Humanities and Social Sciences
Legal and Policy Analysis in Indonesia
article

Regulatory Implications of PPATK's Dormant Account Blocking in Indonesia's Banking System: A Legal Analysis

Najib A. Gisymar, Erna Rusmala, Suyikati Rusmala, Anindita Rusmala, Zaki Sierrad Rusmala
article en

Abstract

This research aims to analyze the regulatory implications and institutional complexities of dormant account blocking policies implemented by Indonesia's Financial Intelligence Unit (Pusat Pelaporan dan Analisis Transaksi Keuangan - PPATK) within the Indonesian banking system, focusing on regulatory harmonization, institutional coordination, and the balance between anti-money laundering enforcement effectiveness and customers' fundamental rights protection. This study employs a normative juridical method with conceptual and comparative approaches toward international regulatory frameworks. Primary data comprises anti-money laundering legislation, banking regulations, and consumer protection laws. Secondary data was collected through systematic literature studies of 50 academic publications from the 2022-2025 period indexed in Scopus Q1-Q3 and Web of Science, alongside analysis of international regulatory practices, Master’s Thesis and Doctor Philoshopy. Data analysis was conducted qualitatively using legal interpretation techniques and gap analysis between normative provisions and practical implementation. Research findings reveal five primary regulatory problems: (1) absence of firm legal definitions regarding dormant accounts in Indonesia's regulatory framework; (2) authority imbalance between PPATK under Law No. 8 of 2010 and procedural due process principles; (3) coordination disharmony among supervisory institutions (PPATK, Financial Services Authority, and Bank Indonesia) creating regulatory overlap; (4) regulatory impacts on financial inclusion and banking service accessibility; and (5) urgent need for regulatory frameworks integrating financial privacy protection under Law No. 27 of 2022.. This research provides theoretical contributions to banking law dogmatics development regarding balanced regulatory approaches between financial supervision functions and consumer protection. Practically, these findings serve as blueprints for responsive regulatory reform integrating anti-money laundering effectiveness with strengthened procedural safeguards, graduated response system implementation, and development of harmonious institutional coordination mechanisms.

Humanities and Social SciencesVol. 13(5)
Universitas Widya Mataram Yogyakarta (ID)
Openalex Percentile: Top 53%
Legal and Policy Analysis in Indonesia
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