Indonesian Anti-Money Laundering Criminal Policy of Crypto Tumbler (Mixer) on The Decentralized Exchange

Abstract

Normatively, Crypto Tumblers are not explicitly prohibited under the Anti-Money Laundering Law, the P2SK Law, or OJK regulations, although their use may be associated with money laundering activities. Nevertheless, the automated, decentralized and cross-jurisdictional nature of crypto transactions creates significant criminal procedural challenges under both UU TPPU and KUHAP 2025. Given Crypto Tumblers positive role in protecting financial privacy, blanket criminalization is therefore inappropriate and unrealistic. Accordingly, Indonesia should adopt a graduated prohibition model through clear eligibility criteria, whitelisting by OJK and the classification of transactions involving non-compliant Crypto Tumbler users as suspicious transactions as typically monitored by PPATK.