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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 Companylisted 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 PUBLIKSEKTOR MANUFAKTUR) (Wiwik Utami)

PENGARUH PERBEDAAN KANTOR AKUNTAN PUBLIK DAN GENDER

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

PERAN ETIKA BISNIS DALAM PENEGAKAN GOVERNANCE PRINCIPLES

(Majidah)

UNIVERSITAS

MERCU BUANA

PROGRAM STUDI MAGISTER AKUNTANSI

UNIVERSITAS MERCU BUANA-JAKARTA

http://www.maksi.mercubuana.ac.idJl. Menteng Raya No. 29 Jakarta Pusat

Email: [email protected]

TEKUNjurnal 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.4Jin. Menteng Raya No. 29

Jakarta Pusat

Phone (021) 31935454 / 31934471Fax. (021)31934474

Email :[email protected]

DAFTAR ISI :

JurnalTE laah aKUNtansi dan bisnis

ISSN 2085-8752

1 A STUDY OF PROCESS AND PROBLEM SURROUNDING OF TRACING ILLICIT

TRANSACTION (Diaz Priantara)

19 REAKSI PASAR MODAL INDONESIA TERHADAP KRISIS SUBPRIME MORTGAGEDl AMERIKA SERIKAT (Tatang A Gumanti dan Karvina W Palupi)

37 RELATIONSHIP BETWEEN CORPORATE SOCIAL RESPONSIBILITY AND VOLUNTARYDISCLOSURE 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 BIAYAMODAL 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)

JurnalTE 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, yaknisetiap 6 bulan. Tujuan penerbitan jurnal TEKUN adalah untuk menyebarluskan hasil kajianliterature dan riset empiris dari dosen, mahasiswa dan praktisi tentang berbagai isu terkait denganakuntansi dan bisnis. Penyebarluasan kajian ilmiah tersebut sangat penting dan bermanfaat bagikepentingan akademik dan juga praktik bisnis.

Artikel yang dikirimkan ke dewan redaksi TEKUN harus disertai surat pernyataan penulisbahwa artikel tersebut belum pernah diterbitkan/dipublikasikan di media cetak atau elektronik.Artikel dapat ditulis dalam bahasa Indonesia atau bahasa Inggris. Jika artikel merupakan risetempiris 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 riviewdewan redaksi. Pertimbangan pemuatan berdasarkan antara lain: (a) artikel ditulis dengan kaidahbahasa Indonesia (bahasa Inggris) yang benar dan (b) memenuhi persyaratan standar publikasijurnal. Dewan redaksi akan merivisi langsung apabila ada kesalahan yang dapat ditolerir, dan akanmengembalikan kepada penulis apabila dewan redaksi (atas arahan dewan redaksi penelaah ahli)memandang bahwa artikel tersebut tidak layak terbit. Artikel dapat dikirim ke dewan redaksidengan alamat:

MAGISTER AKUNTANSI UNIVERSITAS MERCU BUANAGedung Tedja Buana Lt.4,Jln. Menteng Raya No. 29Jakarta Pusat

Phone (021) 31935454 / 31934471Fax. (021)31934474

Email :[email protected]

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 lebih150 s.d. 400 kata. Jika hasil riset ditulis dalam bahasa Indonesia, maka abstrak ditulisdalam bahasa Inggris, dan sebaliknya. Di akhir abstrak dicantumkan kata Kunci (KeyWords).

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 pustakayang menguraikan teori, temuan dan bahasan penelitian sebelumnya yang dijadikanacuan dalam penelitian. Berdasarkan kajian pustaka maka dirumuskan jawabansementara atas masalah peneltian yang dinyatakan dalam bentuk hipotesispenelitian.

d. Metode riset. Bagian ini terutama menguraikan tentang rancangan, yaitu mencakupjenis penelitian, definisi opersional dan pengukuran variable, model yang digunakan,metode sampling dan metode pengumpulan data, serta metode analisis. Untukpenelitian yang bersifat kualitatif, dapat dijelaskan tentang pendekatan yangdugunakan, proses pengumpulan dan analisis informasi, proses penafsiran, danpenyimpulan hasil penelitian.

e. Hasil dan Pembahasan. Bagian ini menjelaskan hasil penelitian dan melakukanpembahasan atas hasil temuan penelitian.

f. Kesimpulan. Bagian ini berisi kesimpulan atas pembahasan mengenai temuanpenelitian.

g. Implikasi dan keterbatasan. Bagian ini menjelaskan implikasi dari temuan danketerbatasan penelitian. Selain itu apabila dipandang perlu bisa memuat saran bagiriset atau telaah berikutnya.

h. Daftar Pustaka/Referensi. Bagian ini memuat sumber-sumber yang dikutip dalambadan tulisan hasil riset dan bukan bersisi sumber yang tidak diacu di badan tulisan

i. Lampiran. Bagian ini memuat table, gambar, dan instrumen riset, atau segalasesuatu yang mendukung tulisan hasil riset yang penting ntuk dilampirkan.

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

3) Panjang naskah artikel tidak lebih dari 7000 kata dengan jenis huruf courir new ukuran11-12 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 urutsatu (1) dan seterusnya.

6) Kutipan ditulis dengan pedoman sebagai berikut:

a. Satu sumber dan satu penulis : MacGregor (1995) atau dengan nomor halamanMcGregor (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 etal. (1995) atau dengan nomer halaman : Bambang et al. (1995:25) atau (Bambang etal, 1996:25).

d. Lebih dari satu sumber : Yasuda (2000); Surya (1998) atau jika dengan nomerhalaman Yasuda (2000:63);Surya (1998:25) atau (Yasuda, 2000:63;Surya, 1998:25).

e. Sumber kutipan yang berasal dari hasi pekerjaan suatu institusi sebaiknyamenyebutkan akronim dari institusi yang bersangkutan, missal: Bapepam (2002).

7) Setiap hasil riset harus menantumkan daftar pustaka (hanya yang menjadi sumberkutipan), 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 Sahamterhadap 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 AkuntansiVol. 1, No.2, 2010 Universitas Mercu BuanaISSN : 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 membawadampak keruglan uang yang tidak sedikit. Korupsi menjadi perhatian, masalah danmusuh global. Perserikatan Bangsa-bangsa menyebut fraud di sektor swasta sebagaikorupsi. Untuk mendapatkan efek jera terhadap korupsi, selain investigasi terhadapperbuatan korupsi guna menemukan tersangka, barang bukti dan alat bukti, serta jeniskorupsinya, tindakan berupa pelacakan aset untuk memulihkan kerugian karenakorupsi merupakan hal yang esensial juga. Korupsi di sektor publik mendapatkankelebihan karena lembaga penegak hukum mendapat legitimasi hukum dankewenangan atau akses dan jaringan kerja sama antar negara. Kondisi sebaliknyaadalah 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 kerugiankarena fraud di sektor swasta melalui pelacakan aset jarang terjadi. Untuk sektorswasta, tidak ada alternatif lain selain menggunakan jasa konsultan, bukaninvestigator swasta, untuk melakukan pelacakan aset dan hasil temuan konsultandapat 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 publicloss 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 privatesector) react to attack fraud or corruption. They together initiate, form and strengthen supervisorybody, regulation and sanction, people involvement and awareness in fraud combating, antifraud oranticorruption 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,



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 notall 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 fraudaxiom: fraud is hidden. In tracing illicit transactions, fraud is hidden can be replaced with terms

of asset is hidden.



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

Jurnal TElaah aKUNtansi dan bisnis 7

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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



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 orillegal activity

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

Trace and \identify assets jthat have been J

stolen /

/ Establish1 evidence to

1 prosecute

\ official

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Diaz Priantara

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 operatingfraudsters 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 notwork 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

10 Jurnal TElaah aKUNtansi dan bisnis


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 eventaking 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) oraccounting graduate degree. They are TrisaktiUniversity, 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 certainstudent. Not many students have the chance to apply such subjects because job of assettracing 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 tracingand 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 tracingillicit 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



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


Diaz Priantara

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 satisfactoryways 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, legalaudit, forensic accounting/audit and public relations training (Davidsen, 2006: 33).This means thatcapacity building and networking is basic requirement for law enforcement agencies. This factor

relates to internal problem belongs to such law enforcement agency and PPATK.



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

Jurnal TElaah aKUNtansi dan bisnis I 15

Diaz Priantara

combination of skills or interdepartmental works. One of such skills is forensic accounting. Assettracing work is similar to financial analysis if the weight of such work is laid on Financial IntelligentUnit (FIU). Since FIU has important role in feeding clues and testifying the flow of illicit moneytherefore, 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 fraudproceeds. 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 ownershipconfirmation.

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 putserious 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 tracingand 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. Theydepend 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 offraud handling by law enforcement agency are expected by private sector.


it

it

Basel Institute on Governance Tracing Stolen Assets (2009). A Practitioner's Handbook.International Centre for Asset Recovery. Basel, Switzerland

r

j Center for Democracy and Governance, Bureau for Global Programs, Field Support, andResearch, United States Agency for International Development (USAID). February 1999.

} Technological Publication Series: a Handbook on Fighting Corruption

Komisi Pemberantasan Korupsi (2006). Laporan Tahunan (Annual Report) 2005. Jakarta

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and International Studies -The United States- Indonesia Society

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The Association of Certified Fraud Examiner. Report to The Nation of 2004, 2006, 2008AI

The Association of Certified Fraud Examiners (2003). Fraud Examiners Manual. Texas

Theodorus M. Tuanakota (2007). Akuntansi Forensik dan Audit Investigatif. LPFEUI. Jakarta

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A Study Of Process And Problem.

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