Police Order to Suspend AMPB Account Raises Questions Over Legal Basis

On Friday, 21 August 2026, the Bank Mandiri account belonging to Supriyono, known as Botok, Coordinator of the Aliansi Masyarakat Pati Bersatu (AMPB), was frozen while he was leading a demonstration in front of the House of Representatives (DPR) building — as reported by Narasi via its official Instagram account on Monday, 24 August 2026. The account reportedly held a balance of around Rp80.9 million, sourced from personal funds and public donations intended to cover the operational costs of the demonstration.

Bank Mandiri subsequently explained that the freeze, carried out on 21 August 2026, was a follow-up to a request from law enforcement and had complied with applicable procedure. However, the Head of PPATK (Indonesia's Financial Intelligence Unit), Ivan Yustiavandana, denied that the order to freeze the account had come from his agency (Tempo, 24 August 2026). In response, the Jakarta Metropolitan Police (Polda Metro Jaya) clarified that the letter submitted by investigators from its Special Crimes Directorate was not an order to freeze the account, but rather a temporary suspension of transactions under Article 26 of Law No. 8 of 2010 on the Prevention and Eradication of Money Laundering ("AML Law"), citing a suspected violation of Article 237 of Law No. 4 of 2023 on the Development and Strengthening of the Financial Sector ("P2SK Law"). This provision requires a corporate-entity licence for activities involving the collection of public funds.

The suspension applied for five (5) working days, with the stated purpose of tracing the intended use of the funds collected. According to Polda Metro Jaya, if the investigation found no indication of a criminal offence, the account would automatically be reopened by the bank. Conversely, if indications of a criminal offence were found, for example, funds deliberately channelled to disrupt security in Jakarta, the case would be investigated further. After the investigation found no criminal offence, Supriyono's account was reopened by the bank on Monday, 24 August 2026.

A Statement That Opens the Can of Worms

Rather than putting public concern to rest, the explanations given by Bank Mandiri and Polda Metro Jaya raise a number of fundamental questions:

1. Does Botok's collection of donations for activism-related purposes fall within the activities prohibited under Article 237 of the P2SK Law?

2. Can Polda Metro Jaya investigators use the transaction-suspension mechanism under the AML Law to pursue a suspected violation of Article 237 of the P2SK Law?

3. If that mechanism can indeed be used, was the procedure for doing so actually followed in accordance with applicable law?

The Fund-Collection Provision under the P2SK Law

Article 237 of the P2SK Law prohibits the collection of funds and/or distribution to the public without a licence. Historically, this provision has targeted practices such as fraudulent investment schemes, illegal chain-referral savings clubs (arisan berantai), or shadow banking. It refers to parties drawing in public funds in a bank-like manner without holding an OJK/BI licence, illegally performing a financial intermediation function by collecting public funds under the promise of returns or financial-institution-style management.

An account holding voluntary donations from supporters of a demonstration does not meet the elements of "collecting funds from the public and/or distribution to the public" in this sense, because:

• there is no offer of a return (it is not investment in nature);

• there is no claim to be acting as a financial institution; and

• the funds are received as donations, not as capital contributions or deposits, and not to be distributed to other parties as loans or other financial products. 

Coherence between Article 237 of the P2SK Law and the Transaction-Suspension Mechanism under the AML Law

The AML Law provides for three distinct mechanisms: (i) temporary cessation by PPATK (Articles 65–66); (ii) transaction suspension by law enforcement (Article 70); and (iii) freezing by investigators (Article 71). Based on the chronology and the statements from PPATK and Polda Metro Jaya, it can be inferred that Article 70 of the AML Law is the provision that was used.

Article 70 authorises investigators, prosecutors, or judges to order a Reporting Party to suspend transactions involving assets known or reasonably suspected to be the proceeds of a criminal offence. The order must be issued in writing and must clearly state: (a) the name and position of the party requesting the suspension; (b) the identity of the party whose transactions are to be suspended; (c) the reason for the suspension; and (d) the location of the assets.

Two problems arise from applying this provision to Supriyono's case:

First, the substantive precondition has not been met definitively. For Article 70 of the AML Law to apply, there must be a strong indication that (a) a predicate offence has occurred as referred to in Article 2(1) of the AML Law, and (b) the funds in the account constitute the proceeds of that offence. Donations from supporters to a demonstration coordinator do not carry the character of proceeds of crime. They are, instead, a voluntary transfer of funds for a constitutionally legitimate purpose, namely the right to assemble and express opinions in public as guaranteed by Article 28 of the 1945 Constitution. In this case, the suspension was carried out precisely in order to trace the purpose of the fundraising, rather than because there was already preliminary evidence that an offence had occurred. A suspension resting on such a thin basis also sits uneasily alongside Article 28H(4) of the 1945 Constitution, which guarantees every person's right to private property and prohibits the arbitrary seizure of that right. Read together with the timing, i.e. a planned demonstration on 27 August 2026, this pattern risks being perceived as an attempt to constrain public expression by intervening in people's assets.

Second, the formal requirement of a written order may not have been satisfied. Article 70 requires a written order that clearly states the identity of the party concerned, the reason for the suspension, and the location of the assets. If the communication received by Bank Mandiri did not meet this formal completeness, the implementation of Article 70 may be considered procedurally deficient.

Competing Interests: Deference to Authorities vs. Customer Protection

The most significant impact of this precedent is perhaps not the Supriyono case itself, but what it signals to the public about the security of their own accounts. Banking is fundamentally built on trust: customers entrust their salaries, savings, and emergency funds to banks in the belief that those funds are safe and accessible when needed. Law No. 10 of 1998 as amended (“Banking Law”) makes this explicit: deposits are defined as funds entrusted by the public to a bank, and the elucidation of Article 20A states that banks operate primarily with public funds held on the basis of that trust.

This trust gives rise to concrete legal obligations. Banks are bound by the prudential banking principle, which requires that any action affecting a customer's rights be grounded in a clear legal basis, procedure, and documentation, as affirmed by Article 20A of the Banking Law. This is reinforced by Article 3(2) of OJK Regulation No. 22 of 2023, which requires banks to apply fair treatment, responsible business conduct, and protection of consumers' assets, privacy, and data.

As a consequence, a bank cannot treat every request from the authorities as an administrative instruction to be accepted at face value, particularly where the action in question restricts a customer's access to their own funds. Before acting on such a request, a bank should verify: the authority of the party making the request; the legal and factual basis supporting it; the specific form of action requested; its duration; and the completeness of the official record and any other requirements under applicable law. Failing to uphold these principles carries a risk that extends well beyond a single account, namely, a broader erosion of customer trust, which can in turn affect a bank's customer relationships, its competitive position, and public perception of its governance.