The Liability of Cryptocurrency Exchanger under Indonesian and

Malaysian Anti-money Laundering and Terrorism Financing Act

Franciska Mifanyira S.

and Sophia C. B. Kusumawardhani

Universitas Airlangga, Surabaya, Indonesia

Badan Siber dan Sandi Negara, Jakarta, Indonesia

Keywords: Cryptocurrency, Liability, Financing, Money Laundering, Terrorism.

Abstract: Globalization and digitization require faster and more efficient payment method to enhance business

operation. A new type of digital asset and payment called cryptocurrency was introduced in 2009 along with

its ledger called blockchain. Some states acknowledge cryptocurrency as an alternative currency by allowing

its usage through the stipulation of rules and regulation; while the others stated the other way around. This

research employs a normative legal research based on statutory, conceptual, and comparative approach. By

comparing Indonesian and Malaysian law, this paper concludes that both states recognized cryptocurrency as

an asset or property. Hence, its usage as currency is deemed as ilegitimate. However, in regard to the liability

of cryptocurrency exchanger, both states have different measures. While Indonesia incorporate the liability

under general act, Malaysia has already specified or directly address cryptocurrency in their Anti-Money

Laundering and Terrorism Financing Act.

1 INTRODUCTION

Rapid and uncontrolled information, communication,

and technology development have created challenges

in the form of loopholes in existing laws, economic

development, political and social stability, even racial

well-being. The existing loopholes lead to instability,

uncertainty, and conflict. This is the exact situation

concerning cryptocurrency within the past nine years.

In 2018, many states have acknowledged Bitcoin

(cryptocurrency) as a payment method either through

a written regulation or simply through acceptance.

However, it could be said that there is no less

countries against it due to several reasons. Some

states see cryptocurrency as another form of

transaction method which able to enhance business

transaction’s efficiency. However, this new

technology also come with risk or threat especially

related to its semi-anonimity. The exploitation of

cryptocurrency’s semi-anonymity and decentralized

nature to conduct money laundering, terrorism

financing, and tax evasion is the most stereotype

reason to forbid cryptocurrency’s usage amongst all.

The purpose of this study is to analyze whether

cryptocurrency can be considered as property or not

in accordance with Indonesian and Malaysian law.

Additionally, it explores cryptocurrency exchanger’s

legal standing and liability based on Indonesian and

Malaysian Anti-Money Laundering and Anti-

Terrorism Financing Law

2 MATERIALS AND METHODS

This study uses a normative legal method. In order to

grasp a thorough understanding of the legal issues,

this paper uses statute, conceptual, and comparative

approach in analyzing and identifying the nature of

cryptocurrency as property and the liability of

cryptocurrency exchanger in both states. The

comparison is subjected to Indonesian and Malaysian

law or statute. Literature and news are used as the

supplementary source to strengthen the argument.

3 RESULTS AND DISCUSSION

3.1 The Nature of Cryptocurrency

Cryptocurrency is a virtual monetary unit and

therefore has no physical representation (Berentsen &

Schar, 2018). Hardwin (2014) assumed that

Mifanyira, F. and Kusumawardhani, S.

The Liability of Cryptocurrency Exchanger under Indonesian and Malaysian Anti-money Laundering and Terrorism Financing Act.

DOI: 10.5220/0010049103450350

In Proceedings of the International Law Conference (iN-LAC 2018) - Law, Technology and the Imperative of Change in the 21st Century, pages 345-350

ISBN: 978-989-758-482-4

345

Cryptocurrency is a developed payment alternative

tools in transaction as the subtitutions of Bank

Product. Hence, cryptocurrency could not deprive the

role of Bank as Intermediary Institution or money as

legitimate medium of exchange.

Today, 500 types of cryptocurrencies were

registered and listed in Bitcoin.com. Bitcoin, Ripple,

Litecoin, Ethereum, Dash, and Dogecoin are six

amongst them. Although Bitcoin was first introduced

in 2009, there is still unsettled debate among experts

regarding its and other cryptocurrencies’ nature.

It is

due to the fact that cryptocurrency is being used as a

means of payment, investment, and security. In other

words, cryptocurrency’s nature is determined based

on its usage and institution regulating it.

As a currency, cryptocurrency does not have an

intrinsic value; its price is volatile and mostly relies

on the user’s future expectation (Bakar, Rosbi, &

Uzaki, 2017; Berentsen & Schar, 2018). Furthermore,

cryptocurrency has various transfer value because it

does not geographically bound unless it is centralized

and regulated by the state itself, for example is the

usage of eChiemgaue in Germany (Lee & Low,

2018).

Unlike government-run fiat currency which price

can be stabilized by adjusting the money supply,

cryptocurrency’s price cannot be maintained in such

a way. Moreover, cryptocurrency is not fully accepted

by the public and is not guaranteed by the

government. This make cryptocurrency does not

fulfill the requirement of a payment tool (Bakar,

Rosbi, & Uzaki, 2017; Danella, 2015) especially as it

does not have legal tender status (Yussof & Al-

Harthy).

Not to mention that under Islamic law

perspective, which adhered and referred by Indonesia

and Malaysia, Bitcoin is not a currency because of

Gharar (uncertaintiness based on no underlying

authority) (Bakar, Rosbi, & Uzaki, 2017; Noor &

Pratiwi, 2018). Government in Indonesia

representated by Futures Exchange Supervisory

Board (BAPPEBTI) has set up future perspective for

establishing cryptocurrency status as commodity or

property in the upcoming decree (Lubomir Tassev,

2018).

Thus, cryptocurrency is closer to financial asset or

property than to currency. This statement is supported

by both expert opinions and legislation.

According to Article 499 of Indonesian Civil Code

(1847), property is every goods and rights which can

be subject to ownership right. It includes tangible and

intangible goods, movable and immovable goods, as

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Some economists have explained bitcoin and other

cryptocurrencies as somewhere between currency, commodity, and

financial asset

well as consumable and non-consumable goods. The

process of obtaining the property has to be made

under legitimate title and lawful legal conducts or else

the owner would not protected by law. Meanwhile,

under Section 3 of Act 613 on Malaysia Anti-Money

Laundering, Anti-Terrorism Financing and Proceeds

of Unlawful Activities Act 2001 (AML/TF) (2015) or

Section 130

of Act 574 on Malaysia Penal Code

(2015), property is defined as “assets of every kind …

or legal documents or instruments in any form,

including electronic or digital…”. From the

stipulation above, it can be concluded that both states

recognized cryptocurrency as an asset or property

rather than currency. The like provision is reflected in

Central Bank of Malaysia Act 2009, Part III Section

20 Central Bank of Malaysia Act 1958 and Article 1

Number 2 Juncto Article 21 Law Number 7 Year

2011 on Indonesia Currency.

Mufti Muhammad Abu-Bakar (2018) in his paper

emphasized that there are two attributes to consider

something as property; those are first, it is desirable

for human beings and second, it is capable of being

stored for use at the time of necessity. Prof. Shawn

Bayern as cited by J. Dax Hansen and Joshua L.

Boehm (2017) stated that Bitcoin (cryptocurrency)

does not fit neatly into classical property categories;

however, it is a new kind of asset in a meaningful

sense. He assessed it based on its functional

perspective in order to avoid arbitrary and unfair

outcomes (Hansen & Boehm, 2017). Kevin O’ Leary,

a Canadian Businessman, Founder of O’Leary Fund

and Softkey also agree on deciding that Bitcoin is an

asset because it has its own inherent value based on

what people will pay for it (Montag, 2017).

It is undeniable that cryptocurrency, Bitcoin for

instance, is valuable to its holder. The fact that it is an

important economic right to those who participate in

the network justifies the criminalization of its theft.

Russia’s Justice Minister, Alexander Konovalov

emphasized that if cryptocurrency was not considered

as property, then its theft would not be a criminal

offense as the object of the crime does not exist

(Tassev, 2018).

Someone who wants to own cryptocurrency (e.g.

Bitcoin), can earn it through mining; purchasing; or

exchanging it with fiat money to cryptocurrency

through exchangers, marketplaces, or traders; and/or

get a payment in cryptocurrency for goods delivered

or services s/he provided. Bitcoin in someone’s

Bitcoin Wallet, shall be deemed as personal property

owned by the holder of that digital wallet. Those who

“legal tender” status can only be issued by authorized national

body such as Bank Indonesia and the Central Bank of Malaysia.

iN-LAC 2018 - International Law Conference 2018

346

own such property shall have the right of ownership;

which under Article 528 jo. 548 (Indonesian Civil

Code, 1847) includes the right to bequeath,

enjoyment, and to defend its possession.

Although cryptocurrency does not have a physical

form, it is still valuable because earning

cryptocurrency through mining is not easy and

purchasing them with cash is not cheap either. From

the explanation above, it is justifiable to conclude that

cryptocurrency should be treated as intangible and

movable personal property.

3.1.1 Liability of Exchanger

Blockchain is a data file that carries the records of all

past transactions using cryptocurrency, including the

creation of new units (Berentsen & Schar, 2018). The

first block of Bitcoin blockchain, block #0 was

created in 2009; and in the first quarter of 2018, block

#494600 was added (Berentsen & Schar, 2018). In

other words, blockchain is a network consists of

database equipped with built-in security and internal

integrity. Its security system is trustable as it utilized

proof mechanism on all the connected networks

called “Decentralized Trustless Transactions”

(Melanie Swan, 2015). There are three parties

involved in a blockchain or cryptocurrency

transaction.

This paper will use “user” as a person

who obtains cryptocurrency to purchase and/or from

selling goods or services (end user). The second party

is “exchanger”, a person who engaged as a business

in the exchange of cryptocurrency for real currency,

funds, or other virtual currency. The third party is

“administrator”, a person who engaged as a business

in issuing or putting the cryptocurrency into

circulation. S/he also has the authority to redeem or

withdraw it from circulation. Both exchanger and

administrator are money transmitter if they accept and

transmit a convertible virtual currency; or buys or

sells convertible virtual currency (Department of the

Treasury Financial Crimes Enforcement Network,

2013).

For example, in a Bitcoin blockchain, Satoshi

Nakamoto is the administrator. While Ana and

Ahmad, are the users who bought or exchange their

money for Bitcoin in Happycoins, who is an

exchanger in South East Asia region. It could be said

that blockchain is such a sophisticated technological

invention that promotes free of double spending

problem, decentralized network without third party

interruption, and lower transaction costs. Even so, it

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These are the adaptation of User, Exchanger, and Administrator

from the Department of the Treasury Financial Crimes

Enforcement Network’s Guidance No. FIN-2013-G001 issued on

is not free of risk especially to the parties. Due to its

pseudo-anonymity, it is possible for Ana (the user) to

purchase drugs and weapons or for Ahmad to offer

criminal services. In some cases, it is possible for

Happycoins (the exchanger) to be caught as the

facilitator of money laundering or terrorism

financing. The example can be seen in BTC-e case

where BTC-e, an exchanger, was fined for facilitating

ransomware, dark net drug sale (Anti Money

Laundering Centre, 2017; Troeller, 2016 - 2017).

That is why this paper will focus on the exchanger’s

liability based on the anti-money laundering and anti-

terrorism financing act (AML/TF act).

The jurisdiction in processing exchanger’s crime

and/or liability is not strictly limited to national law.

It is possible for the perpetrator to be trialed under

international or other national law if the crime s/he

committed affecting other states. In this case,

extraterritorial jurisdiction based on active and

passive nationality principle, protective principle, and

universal jurisdiction as well as the form of

responsibility referred into two various such as

Individual Responsibility and Command

Responsibility (Respondeat Superior) may apply.

3.1.2 Liabitity under Indonesian Law

According to Ronald Waas, using cryptocurrency in

a transaction broke three laws, namely Indonesian

Currency Law, Indonesian Banking Law, and

Information and Electronic Transaction Law in

regard to its appliances (Tempo.co, 2014). He added

that Indonesia Central Bank will not strictly prohibit

its usage. Cryptocurrency transaction and business do

not comply with the stipulation of Bank Indonesia

Regulations Number 18/40/PBI/2016 on Payment

Transaction Management and Number

19/12/PBI/2017 on Finance Technology

Management. These regulations clearly prohibit

every Payment System Service Provider (PJSP) to use

Virtual Currency. If they insist to carry it out, then

Central Bank would revoke their license. To

emphasize their intention, Indonesia Central Bank

made a Press Conference Number 20/4/Dkom on

Virtual Currency and stated that they do not recognize

any cryptocurrency as currency and pointed out its

weaknesses in protecting its consumers. However, in

order to avoid vacuum of law while tackling and

preventing illegal use of cryptocurrency, Indonesia

government may impose Act Number 8 Year 2010 on

Prevention and Eradication of Money Laundering and

March 18, 2013 regarding the Application of FinCEN’s

Regulations to Persons Administering, Exchanging, or Using

Virtual Currencies

The Liability of Cryptocurrency Exchanger under Indonesian and Malaysian Anti-money Laundering and Terrorism Financing Act

347

Act Number 9 Year 2013 on the Prevention and

Eradication of Terrorism Financing towards

exchanger.

Under Indonesian law (Act Number 8 Year 2010

on the Prevention and Eradication of Money

Laundering, 2010; Act Number 9 Year 2013 on the

Prevention and Eradication of Terrorism Financing,

2013), exchanger is obliged to practice “know your

customer” (KYC) principle; report suspicious

transaction

; keep the user’s identity record and

documents for at least five years; as well as to refuse

and cut any ties with shady users or those who do not

want to comply with the terms and conditions. The

KYC principle must incorporate at least the user’s

identification, verification, and transaction

monitoring. If they fail to do so and their user(s) is

identified as conducting money laundering and/or

terrorism financing through cryptocurrency, then they

will be held liable for accepting and exchange the

money into cryptocurrency. Exchangers cannot claim

that they did not know and use it as their excuse

because it could be said that by doing so, they are

fulfilling their business’ goal and objective.

When a personal exchanger violated those

obligations, they might be held liable for maximum

twenty years imprisonment and ten billion rupiah

under Anti-Money Laundering Act (2010). In case

the user used the exchanged cryptocurrency for

terrorism financing, then the exchanger will be held

liable for assisting terrorism financing and will be

punished for maximum fifteen years imprisonment

and one billion rupiah (Act Number 9 Year 2013 on

the Prevention and Eradication of Terrorism

Financing, 2013). Meanwhile if the exchanger is a

corporation, according to Article 7 of Anti-Money

Laundering Act (2010) and Article 8 of Anti-

Terrorism Financing Act (2013), the maximum fine

is one hundred billion rupiahs with the possibility of

additional administrative sanction. If they neglect

their obligation to report suspicious transaction, then,

under Article 13 of Anti-Terrorism Financing Act

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A transaction might be considered suspicious if (1) it does not

have a clear economical and business reason; (2) it uses a relatively

big sum of money and/or do it repeatedly; and (3) user or

customer’s transaction outside his/her habit and out of ordinary.

The exchangers are expected to comply with the provisions of the

Companies Act 2016 [Act 777] including the requirement to be

incorporated or registered

The Profilling Risk mentioned in the Guidline is related to the

Customer Risk, Geographical Location, the Product or Service, and

any informations suggesting that the customer is of higher risk.

Along with Profilling Risk, Reporter shall implied the Customer

Due Diligence in Identify, Verify, Identify the Beneficial Owner,

Understand and Obtain the Purpose the Business Relationship. Due

Diligence by Reporter could be implemented as On Going certain

(2013) they can be fined for approximately one

billion rupiah.

3.1.3 Liability under Malaysian Law

Malaysia’s Finance Minister II, Datuk Seri Johari

Abdul Ghani said that the central bank (Bank Negara

Malaysia (BNM)) will not impose a blanket ban on

cryptocurrencies. However, it will ensure digital

currency exchanges (DCEs) comply with

requirements to conduct customer due diligence and

report suspicious transactions to the authorities

(Kumar, 2018). BNM then issued Anti-Money

Laundering and Counter Financing of Terrorism

(AML/CFT) – Digital Currencies (Sector 6)

(BNM/RH/PD 030-2) as an additional guideline for

Act 613 on Anti-Money Laundering, Anti-Terrorism

Financing and Proceeds of Unlawful Activities Act

2001.The Anti-Money Laundering and Anti-

Terrorism Financing Act (2015) stipulated that

exchangers are obliged to: first, register and licensed

by the government.

Second, conduct risk profiling

towards their customers.

Third, conduct customer

due diligence (CDD).

Fourth, keep and maintain

those records for a period of at least six years. If the

fourth obligation is not fulfilled, the exchanger shall

be liable to a fine not exceeding RM 3 million or 5

years imprisonment at most. The risk profiling shall

comply with the Penal Code to prevent any

supporting conducts by using, possessing, dan/or

sharing cryptocurrency as property in facilitating the

commission of terrorism.

Had they fail to conduct CDD and it is identified

that their past customer was conducing money

laundering, according to Section 4, they will be held

liable for a maximum 15 years of imprisonment and

a fine of not less than five times the sum or value of

the proceeds of an unlawful activities or RM 5 million

(whichever is higher) (Act 613 Anti-Money

Laundering, Anti-Terrorism Financing and Proceeds

of Unlawful Activities Act 2001, 2015).

legal conduct such as doing Transaction Screening if there is

reasons to suspect for the purpose (See Section 9.5.1)

Section 16 (3) of Malaysia AML/CFT stipulates that the

exchanger as the reporting institution shall (1) ascertain the

identity, representative capacity, domicile, legal capacity,

occupation or business purpose of their customer; (2) verify the

document, data or information using reliable means; (3) verify the

identity and authority of a customer in the opening of an account,

the conduct of any transaction or the carrying out of any activity;

(4) take reasonable steps to obtain and record information about the

true identity of any person on whose behalf an account is opened

or a transaction or activity is conducted; and (5) take reasonable

steps to verify the identity of natural persons who own or exercise

effective control over a customer who is not a natural person.

iN-LAC 2018 - International Law Conference 2018

348

Section 87 of AML/TF Act (2015) further stated

that if the exchanger is a body corporate or an

association of persons, then, under Respondeat

Superior Principle; the director, controller, officer, or

partner, or those who were involved in the

management shall be held liable unless he proves that

the offence was committed without his knowledge or

consent and that he took all reasonable precautions to

prevent the damages.

4 CONCLUSION

From the research, it is concluded that; firstly,

cryptocurrency is a property due to the absence of

legal tender and government legitimation. However,

it has not clearly stipulated or fully regulated in a

separated legislation. Secondly, under Malaysian law,

cryptocurrency exchanger are protected and

supervised under Anti-Money Laundering and Anti-

Terrorism Financing Law. b Hence, if they fail to

conduct Know-Your-Customer and Prudential

principle or intentionally neglecting their

responsibility, they can be punished for maximum

three million ringgit fines and/or five years

imprisonment. On the other hand, under Indonesian

law, although it is prohibited to use cryptocurrency in

economic transaction, the ownership itself is not

clearly regulated or prohibited yet. However, in order

to avoid vacuum of law, Anti-Money Laundering and

Anti-Terrorism Financing Law shall be used.

According to these Acts, the exchanger may be

punished for maximum twenty years of imprisonment

and/or ten billion rupiah fines.

SUGGESTION

Cryptocurrency is not a usual property that fits in the

traditional groups of property that were known and

regulated under property law. Hence, a new and

elaborated rules or regulation regarding

cryptocurrency is needed to accommodate the

placement of cryptocurrency as a property so that

their owner can be fully protected. It is due to the fact

that the use of cryptocurrency is not only related to

the citizens’ private rights, but also affecting national

monetary and security system.

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