Bank Indonesia (BI) has issued a Circular, No. 11/31/DPNP with the express intent of providing a set of guidelines to facilitate the implementation of the anti-money laundering and prevention of terrorism funding program contained in BI Regulation No. 11/28/PBI/2009 issued on 1 July 2009. The standard guidelines are includes as an attachment to the circular and cover 13 basic subject areas:
Management
Policy - Customer and Enhanced Due Diligence
Risk Based Approach
Receipt, Identification, and Verification
Politically Exposed Persons
Implementation Procedures
Cross Border Correspondent Banking
Fund Transfer Procedures
Internal Controls
Information Management Systems
Human Resources and Employee Training
Policies and Procedures for Implementation of Anti-Money Laundering and Prevention of Terrorism Funding Measures
Document and Report Management
For example, the guidelines go into some detail defining and explaining the manner in which certain transactions might be carried out in order to avoid detection. The guidelines explain the concepts of smurfing and cuckoo smurfing, among others. Smurfing is the avoidance of reporting requirements by breaking related transactions up into multiple amounts and under multiple names. In contrast, cuckoo smurfing involves the transfer of the proceeds of crime through a third party account where that third party is not aware that their account is being used to deal with the proceeds of crime.
Bank Indonesia (BI) has issued a Circular, No. 11/31/DPNP with the express intent of providing a set of guidelines to facilitate the implementation of the anti-money laundering and prevention of terrorism funding program contained in BI Regulation No. 11/28/PBI/2009 issued on 1 July 2009. The standard guidelines are includes as an attachment to the circular and cover 13 basic subject areas:
Management
Policy - Customer and Enhanced Due Diligence
Risk Based Approach
Receipt, Identification, and Verification
Politically Exposed Persons
Implementation Procedures
Cross Border Correspondent Banking
Fund Transfer Procedures
Internal Controls
Information Management Systems
Human Resources and Employee Training
Policies and Procedures for Implementation of Anti-Money Laundering and Prevention of Terrorism Funding Measures
Document and Report Management
For example, the guidelines go into some detail defining and explaining the manner in which certain transactions might be carried out in order to avoid detection. The guidelines explain the concepts of smurfing and cuckoo smurfing, among others. Smurfing is the avoidance of reporting requirements by breaking related transactions up into multiple amounts and under multiple names. In contrast, cuckoo smurfing involves the transfer of the proceeds of crime through a third party account where that third party is not aware that their account is being used to deal with the proceeds of crime.
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