THE URGENCY OF REGULATING BULLION BUSINESS OPERATORS AS REPORTING PARTIES IN THE ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING REGIME

Abstract

Bullion trading, particularly in precious metals such as gold and silver, is a strategic sector in national financial and investment systems. However, due to its high-value, easily transferable nature and prevalence of cash-based transactions, it is highly vulnerable to abuse for money laundering and terrorism financing purposes. Currently, the Indonesian legal framework, especially Law No. 8 of 2010 on the Prevention and Eradication of Money Laundering, does not explicitly list bullion business operators as reporting parties. This paper aims to examine the urgency of regulating bullion traders within the national AML/CTF regime. Using a normative juridical method with statutory and conceptual approaches, this study reveals that the absence of legal obligations for bullion operators creates significant oversight gaps and impedes the effectiveness of Indonesia’s financial surveillance system. Therefore, it is essential to include this sector as a reporting entity to strengthen financial system integrity and deter illicit financial flows.