A. Background

Money Laundering is the concealment of unlawful money or asset derived from criminal activity to enrich oneself. 

Money laundering gets the attention of the Indonesian government (”The Government”) since it is detrimental to Indonesia’s economy and the public in general. Therefore, the Government is dedicated to preventing and eradicating money laundering through one of its institutions, the Indonesian Financial Transaction Reports and Analysis Center (Pusat Pelaporan dan Analisa Transaksi Keuangan - PPATK).

In line with the government, PT Pakuwon Jati Tbk (“The Company”) is committed to the principles of Good Corporate Governance and implements an anti-money laundering policy in our Company.


B. Classifications of Money Laundering

To start with, the process of money laundering is classified into three basic stages: 

  1. Placement is placing the dirty money into a legitimate financial institution or third party.
  2. Layering is to conceal the source of the money by doing a series of transactions from the account where the money was placed to other bank accounts or certain locations.
  3. Integration, is the withdrawal of funds from those destination accounts to be then deposited into legal businesses unrelated to any of the previous transactions so as to make the money look legitimate.


Some things below are often done by the perpetrators to conceal the source of their unlawful that companies must pay attention to: 

  1. Exchanging cash for smaller change or putting cash into deposits or commercial papers
  2. Transferring or granting the money to internal or external parties
  3. Put the money into saving overseas
  4. Use the money to buy commodities or other assets 
  5. Exchanging the money for foreign currencies
  6. Doing transactions in smaller amounts 
  7. Putting the unlawful money into the same place as the money from legal activities
  8. Putting the money into a legal business activity that has no connection with the illegal activity
  9. Buying or transferring assets under an individual’s own name or to a third party without being detected by the financial system
  10. Bartering stuff with cash so as to avoid financial system detection
  11. Using fake identity or third-party identity so that it is difficult to track the location of the perpetrator


C. Preventive Actions

The company has procedures to prevent Money Laundering to happen within the Company itself by doing below actions:

  1. Timely and consistently report every transaction between the Company and third parties as per the criteria set by the Indonesian Financial Transaction Reports and Analysis Center (“PPATK”)
  2. Include the anti-money laundering clause and the penalty in any purchase agreement or leasing agreement between the Company and third parties
  3. Identify and verify all documents from buyers or lessees on the Company’s properties
  4. Identify and verify all documents from Company’s vendors and suppliers
  5. Control and mitigate the risk of money laundering from Companies’ suppliers, vendors, and tenants
  6. Doing active supervision and performance evaluation periodically on tasks and responsibilities on all components of the Company
  7. Doing internal audit periodically within the Company that involves all aspects of the Company


D. Community Participation

To prevent money laundering, other than proactive action from the Company, community participation is also needed not only in the Company, Company’s properties, and hotels but also from outside the company by:

  1. Not buying assets or goods that have unclear ownership
  2. Firmly reject ambiguous gifts or donations
  3. Firmly reject funding unclear causes because the funds might be to fund the activities of terrorism
  4. Not getting involved in any crowdfunding by organization which purposes is unrelated to the organisation’s vision