The Blocking of Dormant Bank Accounts from a Legal Standpoint

During May to July 2025, the Financial Transaction Reports and Analysis Center (“PPATK”) gradually blocked 120 million inactive (“dormant”) accounts. This blocking was done without prior public announcement, causing confusion among the public. PPATK later clarified that the blocking was done to protect the public from money laundering and encourage banks to re-verify dormant accounts. Following numerous reports of the blocking’s impact on people who would make sense to have dormant accounts, such as students and workers abroad, PPATK unblocked all of the accounts on August 06, 2025. The retraction of this policy gave the impression that the blocking of dormant accounts was carried out arbitrarily without careful consideration, even though the policy was intended to strengthen banks’ security systems so they would fulfil their obligations to actively assist in stopping crimes such as money laundering. Therefore, this article will discuss the benefits of implementing dormant account blocking from a legal standpoint.

Banks are classified as one of the parties obligated to report money laundering offenses pursuant to Article 17 Paragraph 1(a) of Law Number 8 of 2010 concerning the Prevention and Eradication of Money Laundering Crimes (“UU TPPU”). Accordingly, banks are obligated to implement the Know Your Customer principle, as stipulated in Article 18 of UU TPPU. The Know Your Customer principle is described as the process of identifying, verifying, and monitoring customer transactions, and its implementation by banks is supervised by the PPATK. If a customer refuses to comply with this process or if the bank suspects the validity of the customer’s data during the process, the bank is required to terminate its relationship with the customer in accordance with Article 22 of UU TPPU and report the matter to PPATK.

Furthermore, banks also have obligations to their customers. According to Article 40 Paragraph 1 of Law Number 10 of 1998 concerning Banking, banks are fully responsible for customer information or personal data. Article 8 of Financial Services Authority Regulation Number 6/POJK.07/2022 of 2022 concerning Consumer and Public Protection in the Financial Services Sector states that banks are responsible for customer losses arising from their negligence. This responsibility of banks to their customers is part of the law that encourages bank participation in intervening financial crimes.

This is related to the definition of money laundering offenses, where Article 607 of Law Number 1 of 2023 concerning the Criminal Code stipulates that any person who places, transfers, diverts, spends, pays, grants, deposits, takes abroad, changes the form, exchanges for currency or securities, hides or disguises the origin, source, location, allocation, transfer of rights, or actual ownership, receives or controls the placement, transfer, payment, grant, donation, deposit, exchange, or uses money that is reasonably suspected of originating from criminal acts can be subject to imprisonment and fines. Therefore, the obligation of banks to monitor and report any irregularities they find is a legal aspect that the PPATK wants to encourage banks to implement more actively.

However, experts argue that the implementation of this law could have negative consequences, namely that an excessive monitoring system could erode customer trust in banks. Aviliani, Deputy Chairperson for Macro-Microeconomic Policy Analysis at the Indonesian Chamber of Commerce and Industry, stated that the disturbance on account holders’ comfort could reduce customer trust in banks. The loss of customer trust in banks could lead to a reduction in bank customers, which could impact the country’s economic stability. Unfortunately, this decline in customer trust can be seen when the Stock Exchange Index of Bank Mandiri and Bank Central Asia weakened on July 30, 2025, immediately after the public responded negatively to the implementation of the dormant account blocking policy.

On the other hand, some experts feel that the PPATK’s policy is quite good, such as Hendra Lembong, President Director of Bank Central Asia, who stated that he welcomed this decision because he felt it was a good opportunity to remind customers to actively use their accounts. Then there was also Alfons Tanujaya, Vaksincom’s cybersecurity expert, who agreed that what the PPATK did needed to be improved, but he also added that the policy is a good one. “This PPATK decision is good. But perhaps the implementation method needs to be improved with synchronization and refinement,” Alfons said when interviewed by Kompas.

In principle, the blocking of dormant accounts is an implementation of UU TPPU, where banks are required to perform verifications and actively monitor their customers to prevent crimes such as money laundering. However, when the blocking was done without prior notice to the public, they created an entirely avoidable public unrest. Aviliani, Deputy Chairperson for Macro-Microeconomic Policy Analysis at the Indonesian Chamber of Commerce and Industry, stated that they should have sent letters to notify the owners of the accounts beforehand. Any sort of public announcement could also lessen the chances of misinformation from spreading such as rumours that it could lead to government seizure of the blocked accounts.

As an implementation of UU TPPU, the blocking of dormant accounts is a form of law enforcement that pushes banks to be more responsible and carry out their legal obligations in preventing crimes. But, PPATK should’ve consulted with an expert in economics beforehand in order to avoid public confusion and mitigate the real chances of hurting the public’s trust in banks.

References:

1. Aprian, D. and Trisnawati, M. (30 July 2025) Bos BCA Soal PPATK Blokir rekening dormant: Bagus Juga, VOI. Link: https://voi.id/ekonomi/500494/bos-bca-soal-ppatk-blokir-rekening-dormant-bagus-juga (Accessed: 06 August 2025).
2. Asia Sanjaya, Y.C. (01 August 2025) PPATK Ungkap tujuan Utama blokir Rekening Yang Menganggur, Bukan Sekadar Cegah Judol, KOMPAS.com. Link: https://www.kompas.com/tren/read/2025/08/01/124500665/ppatk-ungkap-tujuan-utama-blokir-rekening-yang-menganggur-bukan-sekadar (Diakses: 06 August 2025).
3. Estherina, I. (29 July 2025) Kadin: Pemblokiran dormant Jangan Sampai turunkan Kepercayaan Nasabah, Tempo. Link: https://www.tempo.co/ekonomi/kadin-pemblokiran-dormant-jangan-sampai-turunkan-kepercayaan-nasabah–2052502 (Accessed: 06 August 2025).
4. Fitriyani, E. (06 August 2025) PPATK Buka Semua rekening dormant Yang Diblokir, total 122 juta akun, kumparan. Link: https://kumparan.com/kumparanbisnis/ppatk-buka-semua-rekening-dormant-yang-diblokir-total-122-juta-akun-25b8IQPRPDL (Diakses: 06 August 2025).
5. Indraini, A. (30 August 2025) PPATK Blokir 120 Juta rekening Nganggur, 30 Juta Sudah Dibuka, detikfinance. Link: https://finance.detik.com/moneter/d-8042785/ppatk-blokir-120-juta-rekening-nganggur-30-juta-sudah-dibuka (Accessed: 06 August 2025).
6. Sundari (02 August 2025) IHSG Rontok, Saham Perbankan tertekan! Efek Domino dari Blokir Rekening PPATK, VIVA News. Link: https://banyumas.viva.co.id/news/6588-ihsg-rontok-saham-perbankan-tertekan-efek-domino-dari-blokir-rekening-ppatk?page=1 (Accessed: 06 August 2025).
7. Vella Aresta, R. and Esti Pratiwi, I. (21 May 2025) Sudah Tepatkah PPATK Blokir rekening dormant Untuk Cegah Judol? Ini Kata Pakar, KOMPAS.com. Link: https://www.kompas.com/tren/read/2025/05/21/161500265/sudah-tepatkah-ppatk-blokir-rekening-dormant-untuk-cegah-judol-ini-kata?page=all (Accessed: 06 August 2025).