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• VOL 1, No. 2 Maret 2010 ISSN: 2085 - 8752

TEKUN
(JURNAL T.EJL.AAH AKU fclTANSJ DAM BJSNIS)

A STUDY OF PROCESS AND PROBLEM SURROUNDING OF TRACING


ILLICIT TRANSACTION (Diaz Priantara) ^

REAKSI PASAR MODAL INDONESIA TERHADAP KRISIS SUBPRIME


MORTGAGE Dl AMERIKA SERIKAT (Tatang A Gumanti dan Karvina W Palupi)

RELATIONSHIP BETWEEN CORPORATE SOCIAL RESPONSIBILITY AND


VOLUNTARY DISCLOSURE TO FIRM VALUE (Study at Public Company
listed in LQ 45 Index) (Ahalik, Tri Hesti, Wiwik Utami)

DAMPAK PENGUNGKAPAN SUKARELA DAN MANAJEMEN LABA


TERHADAP BIAYA MODAL EKUITAS DENGAN ASIMETRIINFORMASI
SEBAGAI VARIABEL INTERVENING (STUDI PADA PERUSAHAAN PUBLIK
SEKTOR MANUFAKTUR) (Wiwik Utami)

PENGARUH PERBEDAAN KANTOR AKUNTAN PUBLIK DAN GENDER


TERHADAP EVALUASI ETIKAL, INTENSI ETIKAL
DAN ORIENTASI ETIKAL AUDITOR (Venus Gani)

PERAN ETIKA BISNIS DALAM PENEGAKAN GOVERNANCE PRINCIPLES


(Majidah)

PROGRAM STUDI MAGISTER AKUNTANSI


UNIVERSITAS MERCU BUANA-JAKARTA

http://www.maksi.mercubuana.ac.id
Jl. Menteng Raya No. 29 Jakarta Pusat
UNIVERSITAS Email: jurnal_maksi@mercubuana.ac.id
MERCU BUANA
TEKUN
jurnal TElaah aKUNtansi dan bisnis

REDAKSI

Pembina :
Rektor Universitas Mercu Buana
Direktur Program Pascasarjana

Pemimpin Redaksi :
Dr. Wiwik Utami, Ak.MS

Dewan Redaksi:
Dr. Tarmizi Achmad, MBA, Ak (Universitas Diponegoro)
Dr. Eddy Rasyid, Ak (Universitas Andalas)
Dr. Khomsiyah,Ak (Universitas Trisakti)
Dr. Wirawan (Universitas Pancasila)
Dr. Askam Tuasikal (Universitas Patimura)
Dr. Waluyo (Universitas Mercu Buana)
Dr. Majidah (Institut Manajemen Telkom)

Sekretaris Redaksi:
Susanti Komalasari.S.Sos

Tata Usaha/ Sirkulasi


Rudiana
Jumrah

Alamat Redaksi:
Gedung Tedja Buana Lt.4
Jin. Menteng Raya No. 29
Jakarta Pusat
Phone (021) 31935454 / 31934471
Fax. (021)31934474
Email :jumal_maksi@mercubuana.ac.id
Jurnal
TE laah aKUNtansi dan bisnis
ISSN 2085-8752

DAFTAR ISI :

1 A STUDY OF PROCESS AND PROBLEM SURROUNDING OF TRACING ILLICIT


TRANSACTION (Diaz Priantara)

19 REAKSI PASAR MODAL INDONESIA TERHADAP KRISIS SUBPRIME MORTGAGE


Dl AMERIKA SERIKAT (Tatang A Gumanti dan Karvina W Palupi)

37 RELATIONSHIP BETWEEN CORPORATE SOCIAL RESPONSIBILITY AND VOLUNTARY


DISCLOSURE TO FIRM VALUE (Study at Public Company listed in LQ 45 Index)
(Ahalik, Tri Hesti, Wiwik Utami)

57 DAMPAK PENGUNGKAPAN SUKARELA DAN MANAJEMEN LABA TERHADAP BIAYA


MODAL EKUITAS DENGAN ASIMETRIINFORMASI SEBAGAI VARIABEL INTERVENING
(STUDI PADA PERUSAHAAN PUBLIK SEKTOR MANUFAKTUR) (Wiwik Utami)

85 PENGARUH PERBEDAAN KANTOR AKUNTAN PUBLIK DAN GENDER TERHADAP


EVALUASI ETIKAL, INTENSI ETIKAL DAN ORIENTASI ETIKAL AUDITOR (Venus Gani)

111 PERAN ETIKA BISNIS DALAM PENEGAKAN GOVERNANCE PRINCIPLES (Majidah)


Jurnal
TE laah aKUNtansi dan bisnis
ISSN 2085-8752

KEBIJAKAN DEWAN REDAKSI


DAN STANDAR PENULISAN

I. Kebijakan Dewan Redaksi

TEKUN diterbitkan oleh Magister Akuntansi Universitas Mercu Buana secara berkala, yakni
setiap 6 bulan. Tujuan penerbitan jurnal TEKUN adalah untuk menyebarluskan hasil kajian
literature dan riset empiris dari dosen, mahasiswa dan praktisi tentang berbagai isu terkait dengan
akuntansi dan bisnis. Penyebarluasan kajian ilmiah tersebut sangat penting dan bermanfaat bagi
kepentingan akademik dan juga praktik bisnis.
Artikel yang dikirimkan ke dewan redaksi TEKUN harus disertai surat pernyataan penulis
bahwa artikel tersebut belum pernah diterbitkan/dipublikasikan di media cetak atau elektronik.
Artikel dapat ditulis dalam bahasa Indonesia atau bahasa Inggris. Jika artikel merupakan riset
empiris dengan pendekatan survey atau eksperimen maka harus melampirkan instrumen riset
(kuesioner, kasus, daftar wawancara, dan/atau model).
Penentuan artikel yang layak dimuat dalam TEKUN dilakukan berdasarkan hasil riview
dewan redaksi. Pertimbangan pemuatan berdasarkan antara lain: (a) artikel ditulis dengan kaidah
bahasa Indonesia (bahasa Inggris) yang benar dan (b) memenuhi persyaratan standar publikasi
jurnal. Dewan redaksi akan merivisi langsung apabila ada kesalahan yang dapat ditolerir, dan akan
mengembalikan kepada penulis apabila dewan redaksi (atas arahan dewan redaksi penelaah ahli)
memandang bahwa artikel tersebut tidak layak terbit. Artikel dapat dikirim ke dewan redaksi
dengan alamat:

MAGISTER AKUNTANSI UNIVERSITAS MERCU BUANA


Gedung Tedja Buana Lt.4,Jln. Menteng Raya No. 29Jakarta Pusat
Phone (021) 31935454 / 31934471
Fax. (021)31934474
Email :jumal_maksi@mercubuana.ac.id
II. Pedoman Penulisan Artikel

A. Pedoman penulisan artikel riset empiris adaiah sebagai berikut:


1) Susunan hasil riset setidaknya terdiri atas bagian-bagian berikut ini :
a. Abstrak. Bagian ini memuat ringkasan hasil riset yang terdiri dari : masalah, tujuan,
metode, temuan/kesimpulan. Abstrak disajikan di awal dan penyajiannya kurang lebih
150 s.d. 400 kata. Jika hasil riset ditulis dalam bahasa Indonesia, maka abstrak ditulis
dalam bahasa Inggris, dan sebaliknya. Di akhir abstrak dicantumkan kata Kunci (Key
Words).
b. Pendahuluan. Bagian ini berisi latar belakang (motivasi/isu) riset, permasalahan,
pernyataan tujuan, dan organisasi penulisan hasil riset (apabila dipandang perlu).
c. Rerangka Teoritis dan Pengembangan Hipotesis. Bagian ini berisi kajian pustaka
yang menguraikan teori, temuan dan bahasan penelitian sebelumnya yang dijadikan
acuan dalam penelitian. Berdasarkan kajian pustaka maka dirumuskan jawaban
sementara atas masalah peneltian yang dinyatakan dalam bentuk hipotesis
penelitian.
d. Metode riset. Bagian ini terutama menguraikan tentang rancangan, yaitu mencakup
jenis penelitian, definisi opersional dan pengukuran variable, model yang digunakan,
metode sampling dan metode pengumpulan data, serta metode analisis. Untuk
penelitian yang bersifat kualitatif, dapat dijelaskan tentang pendekatan yang
dugunakan, proses pengumpulan dan analisis informasi, proses penafsiran, dan
penyimpulan hasil penelitian.
e. Hasil dan Pembahasan. Bagian ini menjelaskan hasil penelitian dan melakukan
pembahasan atas hasil temuan penelitian.
f. Kesimpulan. Bagian ini berisi kesimpulan atas pembahasan mengenai temuan
penelitian.
g. Implikasi dan keterbatasan. Bagian ini menjelaskan implikasi dari temuan dan
keterbatasan penelitian. Selain itu apabila dipandang perlu bisa memuat saran bagi
riset atau telaah berikutnya.
h. Daftar Pustaka/Referensi. Bagian ini memuat sumber-sumber yang dikutip dalam
badan tulisan hasil riset dan bukan bersisi sumber yang tidak diacu di badan tulisan
i. Lampiran. Bagian ini memuat table, gambar, dan instrumen riset, atau segala
sesuatu yang mendukung tulisan hasil riset yang penting ntuk dilampirkan.

2) Artikel ditulis dengan jarak baris dua pada kertas kuarto (8,5"x11") penyerahan hasil riset
sebanyak 2 eksemplar dan disertai disket ukuran 3.5". Untuk tabel dan kutipan langsung
yang panjang lebih dari 5 baris (>5 baris) diketik dengan jarak baris satu dengan bentuk
berinden (indented style).

3) Panjang naskah artikel tidak lebih dari 7000 kata dengan jenis huruf courir new ukuran
11-12 atau maksimal 20 halaman kuarto, dan margin atas bawah kiri-kanan sekurang-
kurangnya sati inci (1").

4) Halaman muka (Cover) menyebutkan judul dan identitas penulis.

5) Tabel diketik dengan jarak spasi satu, judul tabel diletakan di atas dan diberi nomor urut
satu (1) dan seterusnya.

6) Kutipan ditulis dengan pedoman sebagai berikut:


a. Satu sumber dan satu penulis : MacGregor (1995) atau dengan nomor halaman
McGregor (1995:25.
b. Satu sumber dan dua penulis : Nailsen, J..and B.P. Warkentin (1995) atau
(Nailsen.J. and B.P. Warkentin (1995:25) atau (Nailsen, J.and B.P. Warkentin,
1995:25). Atau dengan nomor halaman : Nailsen, J. and B.P. Wakkentin (1995:25)
atau (Nailsen, J. and B.P. Warkentin, 1995:25).
c. Satu sumber dan lebih dari dua penulis : Bambang dkk. (1995) atau Bambang dkk,
1996), atau jika dengan nomor halaman : Bambang dkk (1996:25) atau Bambang et
al. (1995) atau dengan nomer halaman : Bambang et al. (1995:25) atau (Bambang et
al, 1996:25).
d. Lebih dari satu sumber : Yasuda (2000); Surya (1998) atau jika dengan nomer
halaman Yasuda (2000:63);Surya (1998:25) atau (Yasuda, 2000:63;Surya, 1998:25).
e. Sumber kutipan yang berasal dari hasi pekerjaan suatu institusi sebaiknya
menyebutkan akronim dari institusi yang bersangkutan, missal: Bapepam (2002).

7) Setiap hasil riset harus menantumkan daftar pustaka (hanya yang menjadi sumber
kutipan), dengan pedoman sebagai berikut:
a. Daftar referensi disusun alfabetik sesuai dengan nama penulis atau nama institusi.
b. Susunan pengetikan adalah : nama penulis, tahun publikasi, judul hasil riset atau
judul buku, nama jurnal atau penerbit, volume atau Edisi, nomer halaman.

Contoh :

Bandi dan Jogiyanto. (2000). Perilaku raksi Harga dan Volume perdagangan Saham
terhadap Pengumuman Dividen. Jurnal Riset Akuntansi Indonesia, Vol.3 No.2:201-
216.

Reuter D.J. and J.B Robinson. (1998). Plant Analyisis : An Interpretation Manual,
Inkata Press, Sydney.
jurnal TElaah aKUNtansi dan bisnis Magister Akuntansi
Vol. 1, No.2, 2010 Universitas Mercu Buana
ISSN : 2085 - 8752

A STUDY OF PROCESS AND PROBLEM SURROUNDING OF


TRACING ILLICIT TRANSACTION

Diaz Priantara
(Universitas Mercu Buana)

Abstrak
Korupsi dapat terjadi di sektor swasta dan publik. Korupsi pasti membawa
dampak keruglan uang yang tidak sedikit. Korupsi menjadi perhatian, masalah dan
musuh global. Perserikatan Bangsa-bangsa menyebut fraud di sektor swasta sebagai
korupsi. Untuk mendapatkan efek jera terhadap korupsi, selain investigasi terhadap
perbuatan korupsi guna menemukan tersangka, barang bukti dan alat bukti, serta jenis
korupsinya, tindakan berupa pelacakan aset untuk memulihkan kerugian karena
korupsi merupakan hal yang esensial juga. Korupsi di sektor publik mendapatkan
kelebihan karena lembaga penegak hukum mendapat legitimasi hukum dan
kewenangan atau akses dan jaringan kerja sama antar negara. Kondisi sebaliknya
adalah jika terjadi korupsi di sektor swasta. Meskipun sektor publik memiliki kelebihan,
ternyata kegiatan pelacakan aset masih belum optimal. Masalah kelembagaan,
koordinasi dan komunikasi serta kapasitas merupakan sebab. Pemulihan kerugian
karena fraud di sektor swasta melalui pelacakan aset jarang terjadi. Untuk sektor
swasta, tidak ada alternatif lain selain menggunakan jasa konsultan, bukan
investigator swasta, untuk melakukan pelacakan aset dan hasil temuan konsultan
dapat diteruskan secara perdata atau menjadi dasar kompensasi jika dipidanakan.
Keywords: asset tracing and recovery, follow the money, follow the suspects, UNCAC

1. Background

Today most people around the world have been treating the fraud or corruption as public
enemy. It is plausible because the impact of fraud or corruption is monumental. The Association of
Certified Fraud Examiner (ACFE) as prominent organization in fighting fraud has always conducted
survey that shows atrocious figures. ACFE reports that fraud loss continues to increase as
reported in the Report to the Nation 2004, 2006, 2008 as follow:
1) Participants in ACFE survey estimated that U.S. organizations lose 7% of their annual
revenues to fraud. Applied to the projected 2008 United States Gross Domestic Product, this
7% figure translates to approximately $994 billions in fraud losses. Similar survey in 2006
reported 5% loss of their annual revenues or USD 652 billions and survey in 2004 reported
loss of 6% of their annual revenues or USD 660 billions

2) Occupational fraud schemes tend to be extremely costly. The median loss caused by the
occupational frauds in this study was $175,000. More than one-quarter of the frauds involved
losses of at least $1 million. Survey in 2006 showed almost one-quarter of the frauds involved
losses of at least $1 million.

I
Diaz Priantara

3) Occupational fraud schemes often continue for years before they are detected. The typical
fraud in our study lasted two years from the time it began until the time it was caught by the
victimized organization. Survey in 2006 reported median time of eighteen months.
4) United States also noted the dark story for accounting frauds or scandals and these frauds
happened in prominent companies like Enron, World.com, etc. Moreover, the scandals involve
one of the big five of Public Accountant Firm (Arthur Andersen).
Mauro (1997) as excerpted by Center for Democracy and Governance (1999: 5) mentioned
that these economic distortions by corruption deter investment and reduce economic growth. In
quantitative terms, Mauro's analysis of 94 countries suggests that a reduction in corruption of 2.38
points on his 10-point scale would increase a country's annual investment by 4 percent of gross
domestic product (GDP), and would increase annual growth of GDP per capita by 0.5 percent
(Mauro 1997). The World Bank's The State in a Changing World, World Development Report 1997
further refines this relationship between corruption and investment by distinguishing the level of
corruption and the predictability of payments and outcomes. It suggests that investment drops the
most in countries where corruption levels are high but the predictability of payments and outcomes
is nonetheless low.

How about Indonesia? In reality, similar survey or research to ACFE's was never found.
Hence, scarcity of empirical data which shows loss due to fraud in private sector. However, the
fraud or corruption in private sector is beyond out of doubt. We can see the recent embezzlement
and accounting (financial reporting fraud) scandal in PT Bank Century Tbk, PT Asuransi Jiwa
Bakrie, PT Wijaya Karya (Persero), etc. On the other side, we can easily find reports or news
regarding fraud (corruption) in public sector. Former Chief of The Supervisory Agency for Finance
and Development (BPKP) Arie Soelendro has presented public loss caused by corruption during
2004 to April 2005 amounting to IDR 3.551 trillions and USD 74.6 millions1. Of course, the public
loss was founded after the Agency had performed investigative audit and the loss does not include
all losses which are not yet revealed, detected, or informed. The loss does not include audit result
performed by The Supreme Auditor (BPK). Chairman of BPK published public loss amounting to
IDR 166.53 trillions during January-June 2004". Prof. Dr. Soemitro Djojohadikusumo in The
Association of Indonesian Economic Graduate (ISEI) Surabaya, November 1993 said that the loss
caused by corruption was estimated at 30% from development budget'"

2. Reaction to fraud or corruption

Awaking to the huge impact from the fraud or corruption both parties (public and private
sector) react to attack fraud or corruption. They together initiate, form and strengthen supervisory
body, regulation and sanction, people involvement and awareness in fraud combating, antifraud or
anticorruption education and so on. United States issued an Act on July 30, 2002 known as the
2 I Jurnal TElaah aKUNtansi dan bisnis
A Study Of Process And Problem...

'Public Company Accounting Reform and Investor Protection Act' (in the Senate) and 'Corporate
and Auditing Accountability and Responsibility Act' (in the House of Representative) and commonly
called Sarbanes-Oxley, Sarbox or SOX. The bill was enacted as a reaction to a number of major
corporate and accounting scandals including those affecting Enron. Tyco International. Adelphia.
Peregrine Systems and WorldCom. These scandals, which cost investors billions of dollars when
the share prices of affected companies collapsed, shook public confidence in the nation's
securities markets.

Then American Institute of Certified Public Accountants (AICPA) in October 2002 issued
Statement of Auditing Standards number 99 (SAS 99) "Consideration of Fraud in a Financial
Statement Audit". SAS 99 imposes on auditors the additional responsibility to "plan and perform
the audit to obtain reasonable assurance about whether the financial statements are free of

material misstatements due to fraud." This standard was effective for audits of financial statements

for periods beginning in or after December 15, 2002. SAS 99, which supersedes SAS 82. was
issued partly in response to recent accounting scandals at Enron, WorldCom, Adelphia, and Tyco.
The standard incorporates recommendations from various contributors including the International
Auditing & Assurance Standards Board

Finally fraud combating spread into the United Nations by issuing UNCAC. The United
Nations Convention against Corruption (UNCAC) was adopted by the United Nations General
Assembly in Merida. Yucatan. Mexico, on 31 October 2003 by Resolution 58/4. As of 8 September
2009, there were 140 signatories and the Convention had been ratified, accepted, approved or
acceded by 137 countries (States Parties). UNCAC is the first legally binding international anti-
corruption instrument. The UNCAC obliges its States Parties to implement a wide and detailed
range of anti-corruption measures affecting their laws, institutions and practices. These measures
aim to promote the prevention, criminalization and law enforcement, international cooperation,
asset recovery, technical assistance and information exchange, and mechanisms for
implementation.
The UNCAC is the most recent of a long series of developments in which experts and
politicians have recognized the far-reaching impact of corruption and the need to develop effective
measures against it at both the domestic and international levels. International action against
corruption has progressed from general consideration and declarative statements to legally binding
agreements. While at the beginning of the discussion, measures were focused relatively narrowly
on specific crimes, above all bribery, the definitions and understanding of corruption have become
broader and so have the measures against it. The Conventions' (not only the UNCAC, but the
Inter-American Convention against Corruption, the OECD Anti-Bribery Convention, the African

Union Convention on Preventing and Combating Corruption) comprehensive approach and the
mandatory character of many of its provisions give proof of this development. The UNCAC deals

Jurnal TElaah aKUNtansi dan bisnis | 3


Diaz Priantara

with forms of corruption that had not been covered by many of the earlier international instruments,
such as trading in official influence, general abuses of power, and various acts of corruption in the
private sector. A further significant development was the inclusion of a specific chapter of the
Convention dealing with the recovery of assets, a major concern for countries which are pursuing
the assets of former leaders and other officials accused or found to have engaged in corruption.
Indonesia has ratified UNCAC into Indonesian Act Number 7 year of 2006. This means that
Indonesia has been included in global network to combating fraud or corruption. In addition,
Indonesia has exposed its commitment and seriousness in combating fraud or corruption as well.
UNCAC does not use the term of fraud in identifying fraud in private sector instead UNCAC uses
the term of corruption for private and public sector. It means that illegal acts arising from corporate
fraud is treated as corruption. For example: Article 21 and 22 UNCAC regulates bribery and
embezzlement in private sector is treated as criminal act (corruption).
Will fraudsters (perpetrators) or corruptors be afraid of antifraud or anticorruption programs
which are being spread extensively and intensively across the world or will they stop their play to
defraud the victim? The answer is definitely not as we still recently heard great fraud during 2008-
2009. For example: Satyam Computer Services, India with accounting manipulation and Bernard L
Madoff Investment Securities with ponzy scheme. On March 12, 2009 Madoff was sentenced 150
years in jail and has to pay USD 170 billions. The Judge estimated the fraud loss is USD 64.8
billions. Ramalinga Raju nowadays are in Hyderabad Jail together with his brother B. Rama Raju,
former Board of Director of Satyam. They are facing possible punishment of at least 10 years in
jail.

3. Fraud or Corruption Loss Recovery

One of interesting themes of UNCAC is fraud or corruption loss recovery (loss recovery).
Several years ago, we rarely hear loss recovery or asset recovery and law enforcement agency
was never concerned with asset recovery. According to World Bank-UNODC (2007:1), stolen
assets in developing countries has become severe and serious problems:
a. Global traffic related to revenue from corruption, tax evasion, and others criminal acts
amounting to USD 1 trillions up to USD1.6 trillions per year.
b. Money earned by developing countries officers from bribery is estimated at USD 20 billions
up to USD 40 billions per year. This amount is equivalent to 20-40% official development
assistance.

Stolen assets are always hidden in financial institutions in some developed countries.
Ironically, bribe earned by Government Officials frequently comes from Multi National Company
and lawyer, accountant, and nominee assist money laundering for asset from corruption. Facing
stolen assets problem becomes great challenge and even though some countries like Peru,

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A Study Of Process And Problem...

Nigeria, and Philippines have got impressive achievement in loss recovery, but the process has
taken a lot of time and cost.

World Bank has set up World Bank Group (WBG) and together with United Nations of
Drugs and Crime (UNODC) established Initiative for Stolen Asset Recovery (StAR). In public policy
perspectives, StAR has issued several notes as follows:
a. Generally, according to Peru, Nigeria, and Philippines experiences, developing countries
definitely have great obstacles in asset recovery.
b. Even though there is political willingness to hunt or dislodge stolen asset, weaknesses of
investigation capacity, limitation of law judicial and financial resources will make constraints
in loss recovery process.
c. Law jurisdiction prevailing in other countries where stolen assets are suspected to be
hidden might not be sensitive to response and help the official law request from victimized
countries.

At the simplest level there are two ways to assist developing countries to recover stolen
assets. First of all, to reduce or eliminate the barrier encountered when they try to recover the
stolen assets in different jurisdictions. Finally, to strengthen regulations and institutions which
administer stolen assets, or in other words, to strengthen capability of developing countries to
recover such stolen assets. It can be achieved by strengthening financial intelligence unit capacity
to prevent money laundering, establish and strengthen national agencies for anticorruption, provide
sufficient training for special unit for asset recovery, invite civil society participation and mass
media to assist in observing usage or consumption of recoverable asset.
For Indonesia, a country where corruption cases happened rampantly such cases cannot
be solved thoroughly as the suspect fled the country together with stolen assets, UNCAC can be
exploited to enforce the effort to maximize asset recovery by:
a. Enhance international cooperation among country members in tracing, freezing, seizing,
confiscating, and returning stolen assets which are placed and hidden in foreign countries
b. Enhance international cooperation among country members in data and information
exchange in order to combat corruption and maximize loss recovery
c. Enhance international cooperation among country members for extradition, mutual legal
assistance, and other law enforcement actions

Although UNCAC gives opportunity to maximize loss recovery of stolen assets, it is not an
easy work. There are some steps and strategy to do loss recovery professionally and legally. In our
profession - forensic accounting and fraud examiner, it is called asset tracking or tracing illicit
transactions.

Jurnal TElaah aKUNtansi dan bisnis


Diaz Priantara

4. Tracing illicit transactions

Globalization has given criminals an unlimited number of possibilities especially in offshore


areas to hide deprived assets. One of the most difficult aspects of recovering from fraud is locating
misappropriated assets. Moreover, today's global economy and internationally linked electronic
systems make' it easier for sophisticated white-collar criminals to use more and more complex
financial vehicles to conceal stolen funds in offshore accounts or shell companies.

a. Who can be the agent performing tracing illicit transactions?


When assets have been misappropriated whether by corporations with intricate structures
and businesses, corrupt government officials or individuals attempting to escape legal
restitution, companies or countries must take immediate action to trace and recover lost assets
so they can be returned to their rightful owners. But companies or countries may lack the
necessary resources internally to respond aggressively in a timely manner.
Public sector has the advantage due to law enforcement agency specialized in corruption
eradication has strong authority and legal status given by Act and regulations. And so do police
and prosecutor, even tough they do not have authority as strong as Corruption Eradication
Commission (KPK), they still have authority and legal status to investigate and trace the assets.
Unfortunately, private sector does not have the authority and legal status to perform tracing
of assets. Can private sector in Indonesia call private investigator to assist in asset tracing?
Although there are several firms offering asset tracing service, formally Indonesia does not
recognize private investigator practice. When one has a corporate fraud case and wishes to
bring the case to criminal court, one must submit indictment to Police. Police will investigate and
decide whether the case has sufficient evidences and requirements to be categorized as
criminal event. In line with that, performing asset tracing can not be fully done by private sector.
Private sector then shall submit appeal to the court to freeze and confiscate stolen assets. Prior
to adjudication issued, list of assets to be seized shall be available. It means that private sectors
shall ask Police to help them performing asset tracing.

b. What do agents do when conduct trace of illicit transactions?


According to ACFE Fraud Examiner Manual (2003: 3.701), many tasks and strategies
ought to be carried out by the agent. Because ofcomplexity and difficulty to perform tracing illicit
transactions, there shall be mix competencies (knowledge and skills) and authorities (World
Bank-UNODC, 2009: 21). Tracing ill-gotten assets looted by Marcos took several years and not
all hidden assets can be found and repatriated. According to ACFE Fraud Examiner Manual
(2003: 1.11), the team shall apply investigation concept and therefore shall be aware of fraud
axiom: fraud is hidden. In tracing illicit transactions, fraud is hidden can be replaced with terms
of asset is hidden.

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A Study Of Process And Problem...

First of all, they have to draw family tree of the suspect's family and spouse's. Family tree is
not only made to depict personal identification of suspect but also to depict name of other
people and their relationships with suspect. For this first step, the agents have to analyze
available data from Human Resources Department or other archives and seek information from
population authoritative. The purpose of family tree is as a means of name reconciliation
between initial or official information with clue. The family tree is also used as a mean to know
how the suspect divides the stolen assets to his/her family.
Another tree or map which should be made by investigator is related parties linkage. This
linkage consist the persons or companies who do not have family and marital relationship. This
linkage is aimed at gaining an overview of what private and professional relationships exist
between the parties involved. The outcome of the intelligence gathering process should be
somewhat called 'the big picture' where all the different leads to the parties involved are
included.

Second action is to obtain clues or leads as initial information. Those clues can be sought
by the agents from many sources whether free sources or paid sources. The agents can seek
information at the library, internet, book store, and information provider. This action can easily
be done by the agents. More difficult action in seeking the initial information is performing data
mining and examining carefully the reports, books, invoices, bank records etc as kept by the
victim. For example: credit card statement as found by the agent can be used to trace suspect
behavior (life style), possibility of asset existence (if suspect frequently goes to certain country
and he uses credit card there, then we can assume the suspects own assets there). Clues
availability is prerequisite for asset tracing. Another more difficult action is seeking information
from government agency which owns clues. For example: property tax or loan report can be
used as clues to investigate and trace the assets.
For the more routine asset recovery work, however, the challenge is to identify leads that
can provide sufficient information to warrant further investigation. Box 10 identifies some of the
administrative channels through which cases are identified. These include: on-going
investigations into criminal activity; internal and external audits of government agencies;
suspicious activity reports filed by financial service providers; denunciations by whistleblowers;
discrepancies arising from reviews of income and asset declarations; and investigations into
customs and tax violations. Alongside these internal, administrative channels, civil society and
media reporting has often proved an effective mean of bringing leads to the attention of the
authorities and exerting pressure for prompt, effective follow-up. Leads can also be generated in
financial centers. Where suspicious activity reports are filed by financial service providers
regarding transactions originating or involving individuals from a foreign jurisdiction, there are

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well established mechanisms for communicating this information to the appropriate foreign FIU
or financial intelligent unit (World Bank-UNODC, 2009: 24)
Third action is to develop fraud theory. Similar to investigation process, asset tracer shall
analyze and evaluate all availability data (clues) and hypothesize the possibility of asset
existence and possibility of asset owner relationship with suspect. After hypothesize both
possibilities, asset tracer shall develop strategy to trace or investigate. Similar to investigate
fraud or corruption or white-collar crime, fraud axiom is implemented as well. The suspect will
convert the stolen asset from fraud or corruption to other forms. In order to get the best result,
he/she will conceal or hide the ownership and location of his/her assets.
Forth action is to conduct fraud theory i.e. performing asset tracing or field investigation as
a way to develop and increase clues or strengthening degree of confidence of clues. More
confidence to clues means asset tracer has strong belief that the target asset is owned by
suspect. Like investigation, asset tracer will apply investigation techniques here. Basically, an
asset tracer will apply field investigation like a crime investigator. Although forensic accounting
is important and clue searching is done by data mining or tracing to accounting and financial
records, clues enhancement can not be done without field investigation. The technique most
used in asset tracing is known as follow the money. This method is also effective to trace all the
people involved in corruption or fraud.
The transformation of leads into corruption and asset recovery cases that can be
successfully pursued in court requires the collection of evidence. This is a significant challenge.
Corruption and international laundering of the proceeds of corruption are complex crimes,
requiring analysis of vast amounts of financial and technical documentation, tracing flows of
funds through transactions that are designed to obscure the trail a*nd the use of corporate
vehicles established for the sole purpose of hiding the beneficial owners. Asset recovery
requires skilled analysts, with access to analytical tools and data (World Bank-UNODC, 2009:
26)
Next phase, asset tracer shall seek confirmation of asset existence and ownership to
related authority. Ifasset tracer can not explain direct ownership or if the target asset is named
by nominee, asset tracer shall put it in his/her report clearly how the relationship is and who is
the nominee. At this phase, asset tracer also has to coordinate and cooperate with authority in
his/her country or with authority in other countries. This phase is important due to freezing and
seizing activities need clarity of existence and ownership of assets.
Another very important action which shall be done in the same time as first action is the
asset tracer, especially for asset tracer with legal knowledge, shall study the legal position,
especially for assets under nominee and assets under other jurisdictions. Can we seize and
confiscate the target asset or should we ensure the target asset is bought from fraud or

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corruption proceeds before seizing? Shall we have court adjudication before we submit
application to authority in another country for seizing? For most cases, especially for having
compensation for fraud loss, we only show the list of asset to judge and ask him the
adjudication for seizing. However, the court prefer asset with name of the accused or his/her
spouse and children which will be frozen and seized. In case of target asset in abroad, the
process do not stop until the asset or liquidation of asset is returned to victim. Indonesia has
proposed the regulation for confiscating and seizing the asset proceed from corruption to a new
bill.

Finally, the asset tracing team shall submit the application to freezing, seizing and
confiscate the suspected assets to the court and relevant authorities. The team shall seek good
method and approach in determining how to repatriate or how to get the ill-gotten assets
successfully. This last step is legal area and that is why, all people involved in asset tracing
team with various knowledge and skills at the end shall support law agent as spear. After the
assets successfully returned, another agenda is how to get benefit by such assets and how to
and who are responsible to keep them. Indonesia has proposed this issue to be clauses in a
new bill regarding corruption court
All the above processes in overall can be summarized in figure below. These processes
is suggested by Basel Institute (Basel Institute, 2009: 50), but according to our experiences, it is
true and it is better to be applied consistently by asset tracing team in order to have effective
way and maximum results.

Figure 1 The core goals of the investigative process

Connect Asset
to Corrupt or
illegal activity

/ Goals of \
I investigation 1
l conducted by 1
\ government ^w^

Trace and \ / Establish


identify assets j 1 evidence to
that have been J 1 prosecute
stolen / \ official

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c. What are the skills needed to perform trace of illicit transactions?


Base on above explanation in point b, we can see that many tasks and strategies should be
carried out by the agents. This means they must own combination of competencies or
departments. Such departments are often composed of interdisciplinary teams with different
backgrounds such as law, accounting, Information Technology (IT), law enforcement and
intelligence. Because knowledge and background are shared in such teams, investigations can
be conducted more effectively and efficiently based on this alignment of know-how (Basel
Institute, 2009: 102)

1) Forensic accounting.
The investigator needs to have excellent accounting skills as smart operating
fraudsters and corrupt officials try to hide their tracks through complex accounting and
financial transactions. Today's complex global financial system complicates the detection
of stolen assets significantly, requiring the investigator to know about current
developments and innovations in the financial sector to be able to understand complex
transactions and instruments and how they can be used to hide funds and assets (Basel
Institute, 2009: 102) This financial investigator is called forensic accountant. Forensic
accountant can help trace cash and other valuable assets in the unlawful possession of
third parties. Forensic accountant accomplish this by gathering information about the
misappropriation or embezzlement, finding and reviewing documentation of transfers,
assembling a timeline of suspicious activities and following the money trails, often cross
borders. Forensic accountant can not work alone. Throughout asset search investigations,
he/she frequently works with police and legal officials to prepare charges against the
perpetrators. Experience shows that mastering the entire process of investigation and
legal procedures is a key to achieve the objective of proving fraud and recovering missing
assets. In this process, lawyers and investigators need to work together closely. If not, all
parties involved will end without sufficient information and all efforts will fall flat

2) Investigation
Asset tracing frequently applies field investigation because too much information is
not available through free sources or accounting and financial records which can be done
by forensic accountant, the required information can be frequently captured by on-site
inspections and conducting interviews with third parties, e.g., business partners,
witnesses, creditors and other stakeholders. Conducting interviews should be an ongoing
part of the asset tracing investigation as more and more information becomes available.
This can, in turn, be used for further interviews or in deciding who to approach for further
information. This practice is done by investigator (Basel Institute, 2009: 106). Investigation

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in simple meaning can be defined as an effort to prove some one guilty in accordance to
prevailing laws (Tuanakota, 2007: 207)

3) Computer forensic specialist


In most situations, hidden assets can be identified through discovery. In more
complicated cases, obtaining documents and financial records through the discovery
process is not enough. There may be documents and financial records that exist only in
electronic form.. Increasingly, the investigation process of corruption cases, inclusive of
asset tracing, involves the collation and analysis of large volumes of financial and other
data. In 'following the money trail', investigators need accurate, reliable, comprehensive
and up-to-date information. Information retrieved from the digital media leading to
criminally-gained assets will lead to action to seizure of those assets (Basel Institute: 72)
A forensic computer examiner who can find, preserve and present these records is
needed in order to get effective asset tracing. Computer Forensics is the collection of
techniques, processes and procedures used to extract, analyze, preserve, and present
electronic evidence within criminal or civil court

4) Legal counsel.
This competency consists of international law, criminal law, and civil law. International
law is essential where assets are in foreign countries and its resolution needs international
law framework. Most importantly, a successful investigator needs to be able to rely on
international network of business partners and affiliates located in multiple countries to
ensure a thorough understanding of the local laws and regulations with regard to asset
tracing. This network can also help in conducting business partner screening and even
taking on the asset tracing investigation once a clear link to the respective foreign country
has been established. (Basel Institute, 2009: 104) Legal shall determine whether case
resolution in the form of claim for damage without jail punishment then civil law is
appropriate approach or not.
Can these skills be learned in university? As far as we know from our exploration to
university websites or brochures in Jakarta, we find only a few universities offer forensic
accounting subject. Most of them are in graduate program for accountant profession
(Program Pendidikan Profesi Akuntansi) or accounting graduate degree. They are Trisakti
University, Tarumanagara University, and University of Indonesia. However, students can
learn such subjects but if they wish to be expert, they must have more chances to apply
their knowledge (Golden, 2006: 349). This statement is right and workable for certain
student. Not many students have the chance to apply such subjects because job of asset
tracing or investigation is very rare. Especially for private sector, students who work at

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private sector, even if they work at internal audit division, can not perform asset tracing
and investigation as effective as they are working at legal enforcement.

5) Who will be the user of tracing illicit transactions?


Base on above explanation in point c, we can see that the user of service of tracing
illicit transaction comes from many sectors. Private and public sector need such service
because fraud happens everywhere.

5. Follow the money


To get the best result in investigating fraud or corruption, the investigator must apply two
approaches simultaneously. First, he or she implements follow the suspect. This approach is
designated to find who is the fraudster or corruptor and where does he live. Follow the suspect
means the investigator must search and collect crime proof in proper amount and giving absolute
assurance according to prevailing law. Second, the investigator will conduct follow the money
approach. This approach has a goal to search for money or assets which are indicated owned by
the suspect.
Follow the money is an investigation technique which traces flow of money and seek the
estuary (Tuanakota, 2007: 246). Follow the money has been used long time ago in USA and more
well-known as money laundering. Money laundering was promoted by United Nations in 1988 with
Vienna Convention. Follow the money has priority to search the money or assets first than
searching the suspect. According to Dr.Yunus Huseiniv - Head of Indonesia Financial Transaction
Reporting & Analysis (Pusat Pelaporan dan Analisis Transaksi Keuangan or PPATK), follow the
money is a weapon to find the ultimate responsiliblty holder in financial crime. Most of illegal
logging cases stop to driver, woodcutter, ship captain and almost never to get the government
officer or businessmen who direct them to do illegal logging. However, folow the money can not
stand alone and so do follow the suspect. In order to become effective, two approaches shall be
used simultaneously and complementing. History records how well the follow the money succeed
in disclose bank fraud in BNI (fictitious L/C) and Bank Global.
Although follow the money records success in disclosing bank fraud and mapping all
persons involved in such fraud, it has an obstacle yet. According to Dr.Yunus Husein, this
approach becomes ineffective due to different perception and mind among law enforcement officer
(police as investigator, prosecutor, and judge and police capability to conduct financial
investigation itself).
According to Mallam Nuhu Ribadu, former Executive Chairman of Nigeria's Economic and
Financial Crimes Commission (EFCC) when he said in Regional Seminar for Asia Pacific on
September 5-7, 2007 in Bali (KPK, 2007: x) to be success in following the money and suspects,
the most important factor is strong willingness and seriousness from top level (President for public

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sector or President Director for private sector) and then international cooperation among countries
around the world. He said that as speaker in seminar with theme of making international anti-
corruption standards operational: Asset recovery and Mutual Legal Assistance. In this seminar, he
explained their success in tracing illicit transaction and returning stolen assets of former President
Sani Abacha. He said that follow the money (he said in other term as financial analysis) was
success key of EFCC in tracking and returning assets of Sani Abacha at foreign countries.
Therefore, public participation in submitting suspicious transaction report to Financial Intelligence
Unit is very important.

6. Asset tracing practices in Indonesia.

As a matter of fact, asset tracing in Indonesia has been applied since old order. Learning
from its history, Indonesia was among the first countries that started the fight against corruption
(started 1955) but until 2009 Indonesia is among countries incapable of controlling their corruption
yet. The first effort in combating corruption took place in 1955 when the operation led by Dr.
Soemitro Djojohadikusumo (Minister of Finance) to conduct investigation for departments and
government ministries involving state accountants to find any corruption act or illicit matters
occurred. Aimed to investigate the fund leakage occurred in every departments and ministries. This
effort was one of cabinet program priority at that time.
Secondly, in 1955, led by the CPM (the Police Military, henceforth CPM), conducted by the
Attorney General (Mr. Suprapto) pursuing the arrest of Djody Gondokusumo (former Minister of
Justice) for receiving bribe. Unfortunately the Attorney General could not arrest this former of
Minister of Justice, because Attorney General is under of Ministry of Justice. So, when the cabinet
dismissed and the minister of justice finished; he was arrested afterwards. According to the
investigation methodology, after the minister ofjustice arrest, CPM conducted search and seizure
of the assets, while these are the standard process of the beginning of investigation. In years, this
methodology of process had not been used by the government or officials in investigating or
prosecuting corruptors, until KPK started using this methodology nowadays. Many people think
that KPK invent this methodology, whereas KPK just follow the procedure from the previous
investigators7.
Indeed, before KPK uses asset tracing, during 2000 until 2004 there was forensic and asset
tracing unit (FORSAT) under Indonesian Bank Restructuring Agency (IBRA). This agency performs
forensic accounting and asset tracing separately or simultaneously to support core divisions at
IBRA in solving the great problems at that time related to Bank Indonesia short funding (BLBI),
bank fraud, legal resolution (criminal or civil, non-litigation or litigation). Coincide with dismissal of
IBRA, FORSAT got the same destiny. Until now, the output of FORSAT works is not clearwhether

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it is still used by law enforcement agency and finance ministry or not. KPK, according to its annual
report of 2005 started asset tracing and recovery in late of 2005.
Comparing with one decade ago orolder decade, recent condition brings more satisfactory
ways in tracing illicit transaction.
1. Some regulations have been issued and some institutions were established. For example: Anti
Money Laundering and Financial Intelligence Unit becomes a critical and the most important
unit in anticorruption effort, Mutual Legal Assistance and UNCAC ratification brings Foreign
Minister and Law Minister involved in anticorruption effort.
2. Corruption and fraud becomes global attention and the most interesting news. United Nations,
World Bank, and other donors race to give support to developing countries to strengthen their
regulations, human resources, capacity building of law enforcement agency. Many
conferences were organized to take participation and to make coordination among participant
countries. KPK and other law enforcement agencies have already got many benefits from
donors in forms of training, information sharing, etc.
This good climate should be used properly by all law enforcement agencies. However, the
result of asset tracing is still not satisfying. For example: rumors regarding assets belong to ECW
Neloe (Bank Mandiri case), Hendra Raharja (Bank Harapan Sentosa case), Irawan Salim (Bank
Global case), Edi Tansil (Bank Pembangunan Indonesia case) are still not returned by Tim
Pemburu Koruptor (Corruptor Hunter) yet which led by Attorney General. The same result as TPK,
with public budget amounting to IDR 247.68 billions used by KPK during 2004-2006, KPK only
succeeded to return public loss amounting to IDR 50.04 billions'", but KPK showed improvement
during 2008, KPK used publicjDudget amounting IDR 264.19 billions and saved IDR 460 billions
and assets IDR 200 billionsvii *
Then many people think why asset tracing still slow and do not bring significant money.
KPK reported that the limited recovery of assets from corruption proceeds is another home work in
eradicating corruption, apart from the conviction of the corruptors, the recovery of assets from the
corruption proceeds is yet to be executed to create a deterrent effect. The fact being that the
amount of asset recovered against the accumulated loss to the state judged by courts is still very
small. This is attributed to many causes but one of them is the incompetence of law enforcers to
trace corrupter's assets which have gone through a number of placements through financial and
banking transactions. This calls for enhancement of knowledge in financial and banking
transactions and close relationship with other institutions such as PPATK (KPK, 2006: 19)-
Indonesia shall increase the capacity of law enforcement officials: Provide asset tracing, legal
audit, forensic accounting/audit and public relations training (Davidsen, 2006: 33).This means that
capacity building and networking is basic requirement for law enforcement agencies. This factor
relates to internal problem belongs to such law enforcement agency and PPATK.

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il Another problem relates to outside law enforcement agency i.e. foreign law dealing and
prevailing laws and regulations do not support asset tracing. Even though Indonesia has ratified
/ UNCAC, Indonesia needs new bills and must amend existing laws and regulation in accordance
with UNCAC. Political will from President of Indonesia is not doubtedv'". He has issued instruction
;i for eradicating corruption (Inpres Pemberantasan Korupsi). Government also issued asset
t recovery (confiscation) bill, old bill regarding anticorruption and criminal laws are being harmonized
) with UNCAC. Regarding foreign law barrier, Article 46 paragraph (1) UNCAC has tried to break it,
States Parties shall afford one another the widest measure of mutual legal assistance in
investigations, prosecutions and judicial proceedings in relation to the offences covered by this
Convention". This barrier has been realized by many countries and world organizations. Therefore
' for upcoming years, in order to succeed in asset tracing abroad then theme of different law and
administration procedures among state parties will be important and critical problems.
i Despite of KPK, Government Agencies had shown their concern to asset tracing and
recovery. Ministry for Coordination of Politic, Defense and Security had given his comment that
streamlining implementation asset tracing and recovery is a must in order to increase and
maximise ill-gotten assets returning and all at once giving significant contribution for national
economy development (Tim Penyusun Komite TPPU, 2007: i). Almost all countries which have
great concern to asset tracing emphasize effectiveness of work of financial intelligent unit like
PPATK and PPATK has been giving significant contribution to feed clues. If we follow news at all
times, we can read statements from top level officials like Foreign Affairs Minister, Attorney
General, and National Police to support asset tracing and recovery. It can be seen when they
established interdepartment officer to trace Bank Century casex.
How about asset tracing if the victim is private sector not public sector? Private sector is a
very contrast condition than public sector as when private sector suffers damage from corporate
fraud or corruption, it has only two opportunities. Private sector can request Police or Consultant to
perform asset tracing. Based on our experiences and interview with some corporate internal
auditors, most of companies solve their fraud case with internal rules like termination and sanction,
and not giving the case to Police for criminal settlement. When fraud damage is considered in big
amount, a few companies ask consultant (not private investigator) to perform asset tracing.
According to our experience and interview, companies are more comfortable and have more
confidence in consultant to solve fraud loss than Police. Bottom line is nobody in victimized
company can perform asset tracing by themselves.

7. Conclusion

Asset tracing or tracing illicit transaction as bigger concept and follow the money as
narrower concept shall be conducted together with follow the subject. Asset tracing needs

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combination of skills or interdepartmental works. One of such skills is forensic accounting. Asset
tracing work is similar to financial analysis if the weight of such work is laid on Financial Intelligent
Unit (FIU). Since FIU has important role in feeding clues and testifying the flow of illicit money
therefore, FIU officer conduct forensic accounting. When fraud is examined, fraud examiner or
forensic accountant shall try to know how and where fraudster or corruptor converts fraud
proceeds. Everything done by FIU or fraud examiners and field investigator basically is intended to
seek initial clues, enhance initial clues, identify and locate suspected assets and do ownership
confirmation.

Nowadays, in order to have deterrence effect asset tracing and recovery can not be
separated or isolated from fraud investigation, asset of fraudster or corruptor shall be sought,
frozen, confiscated, and repatriated. United Nations, prominent organizations and donors have put
serious attention to asset tracing and recovery. United Nations has announced officially UNCAC.
Prominent organizations, state parties, and donors are enthusiastic to conduct bilateral and
multilateral discussion, organize conference and so on regarding anticorruption and asset tracing
and recovery.
Indonesia has ratified UNCAC and MLA, established KPK, and being harmonize prevailing
criminal laws in accordance to UNCAC spirit. Indonesia will issue new bills regarding asset
recovery and seizing and confiscation. Law enforcement agencies, including KPK and PPATK,
have obtained training and other supports from donor or other countries. For public interests
(anticorruption) those are basic capital to foster anticorruption. The great obstacle comes from
different laws and administration procedure. Unless morality and nation spirit nothing else should
be obstacles. Government shall manage properly all working units related to anticorruption and
asset tracing and recovery and utilized effectively all skilled and trained officers.
Unfortunately, private sector does not have basic foundation to enable them to solve fraud
cases since they do not have capacity in performing asset tracing and recovery and investigation,
and moreover they do not have the authority. They depend on Police to solve their corporate fraud
which accomplice with criminal elements or they solve their fraud cases internally. Companies
prefer to request consultant to perform asset tracing and recovery or they solve internally for fraud
recovery. Except state-owned enterprises, private sector still does not have the same access and
attention as public sector. For the future, new or adjusted bills should accommodate private sector
interest to maximize fraud loss recovery. Facilitation to request assistance to Police or other
agencies in corporate fraud investigation and asset tracing and recovery, facilitation to discuss with
law enforcement agency the best solution for fraud happened, facilitation to monitor the progress of
fraud handling by law enforcement agency are expected by private sector.

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it REFERENCES

it
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r

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Stolen Asset Recovery (StAR) Initiative (2007). Challenges, Opportunities, and Action Plan. The
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The Association of Certified Fraud Examiner. Report to The Nation of 2004, 2006, 2008A
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Theodorus M. Tuanakota (2007). Akuntansi Forensik dan Audit Investigatif. LPFEUI. Jakarta

Thomas W. Golden, Steven L. Skalak, Mona M.Clayton (2006). A Guide to Forensic Accounting
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Tim Penyusun Komite TPPU (2007). Strategi Nasional Pencegahan Dan Pemberantasan Tindak
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