Limitation of the Use of Cash in Transactions

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A cash transaction is a transaction method that is commonly used by Indonesian citizens. However, as time goes by, this matter will indirectly lead to particular advantages and disadvantages. Transactions carried out in cash are usually for small-value transactions. On the other hand, non-cash transactions are usually carried out for large-value transactions. However, cash can also be used in large value transactions. This can sometimes lead to money misappropriation. Cash transaction is one of the transactions that are difficult to be detected. In some transactions that are full of crimes such as money laundering and terrorist financing, cash transactions can be a safe choice to carry out.

Nevertheless, up until now, the Indonesian Government has never regulated the limits of the cash transactions, even for Foreign Investment (“PMA“) in Indonesia. The government is in the process of finalizing the bill of Cash Transaction Restriction (“RUU PTUK“). This regulation is very important as one way to prevent the crime of financial transactions, such as bribery, corruption and money laundering.

The RUU PTUK stipulates a maximum limit on the value of cash transactions. Article 3 paragraph (1) states that “Everyone can carry out a Cash Transaction with a maximum value of Rp100,000,000.00 or a value equivalent to that” which means the application of these rules only allows cash transactions to be set at a maximum of Rp100,000,000.00. Furthermore, RUU PTUK prohibits anyone from conducting cash transactions in excess of Rp100,000,000.00, as stipulated in Article 3 paragraph (2) which reads “Everyone is prohibited from carrying out a Cash Transaction with a value of more than Rp100,000,000.00 or a value equivalent to that both in one or several transactions in one day in the territory of the Republic of Indonesia, unless otherwise specified in this Act.

The regulation requires that each transaction with a value of more than Rp100,000,000 be made in non-cash. This non-cash transaction can be carried out on Financial Services Companies (“PJK“) such as banks, postal operators, providers of payment instruments using cards and providers of fund transfers. The legal consequences of violating these rules are in the form of administrative sanctions, with a maximum sanction in the form of cancellation of the non-cash transaction agreement. Article 9 paragraph (1) of RUU PTUK also gives an exception for cash transactions in excess of Rp100,000,000.00. There are 12 types of transactions that are excluded, as follows:

    1. Transactions of cash carried out by PJK with the government and central bank;
    2. Transactions among PJKs in the context of their respective business activities;
    3. Transactions of cash withdrawal from banks in the matter of paying salaries or pensions;
    4. Transactions of tax payment and other obligations to the state;
    5. Transactions to carry out court decisions;
    6. Transactions for money processing activities;
    7. Transactions for medical expenses;
    8. Transactions for natural disaster management;
    9. Transactions for law enforcement;
    10. Transactions for placement or deposit into PJK;
    11. Transactions for the purchase of foreign currency;
    12. Transactions in regions that have not had a PJK, or a PJK is already available but the PJK does not have an adequate payment system infrastructure.

The Team of RUU PTUK states that the maximum limit of transaction value is Rp100,000,000.00, which refers to regulations in various countries. The formulation of the limits on transaction value shall pay attention to aspects of protection of community rights, but these limits must also be effective and efficient in preventing and eradicating Money Laundering (“TPPU“).


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Dendi Adisuryo

Liza Mashita

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This publication has been prepared by Aditya Yudhistira for general informational purposes only to provide clients with information on recent legal developments and is not intended as legal advice or opinion.