Crypto on the Hook for State Receivables Management: State Authorized to Confiscate Digital Assets and Bypasses Debtor Consent for Collateral Use

The Minister of Finance (“Minister”) has issued Regulation No. 23 of 2026 (“Amendment”) on the Amendment to the Regulation of the Minister No. 240/PMK.06/2016 (“Regulation 240/2016”),[1] which has come into force on 24 April 2026.[2] This framework significantly restructures procedures previously governed under Regulation 240/2016 by authorizing the government through the State Receivables Management Committee (Panitia Urusan Piutang Negara – “PUPN”) to physically control (penguasaan fisik), utilize, or lease seized collateral prior to auction without requiring debtor consent.[3]