A Legal Review of the Freezing of Dormant Accounts by Banks at the Request of the Financial Transaction Reporting and Analysis Center (PPATK) and Its Impact on Account Holders

Abstract

The practice of blocking dormant accounts in mid-2025 has attracted considerable public attention. The Financial Transaction Reports and Analysis Centre (PPATK), a state institution, is blocking dormant accounts namely, accounts that have not been used for a certain period of time. However, blocking accounts that are not specifically targeted can raise issues requiring solutions, particularly regarding legal responsibility and resolution. Such actions can also erode public trust in financial institutions and disrupt the economic activities of affected individuals. This study aims to examine the legal framework governing PPATK’s authority to block dormant accounts, the legal implications and losses suffered by depositors, and the legal protections available to depositors. The research employs a normative legal method, analyzing relevant legal provisions, including the Banking Act No. 10 of 1998, the Anti-Money Laundering and Counter-Terrorist Financing Act No. 8 of 2010, the Financial Services Authority Regulation No. 8 of 2023, legal doctrines, and pertinent court rulings. These are then examined theoretically within the framework of legal science. It is expected that PPATK and banks will ensure that blocking actions are conducted selectively, in compliance with applicable provisions, and in a manner that does not cause losses to customers.