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Best Sanctions & Export Controls Lawyers in Mulyorejo

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Indonesia Sanctions & Export Controls Legal Questions answered by Lawyers

Browse our 2 legal questions about Sanctions & Export Controls in Indonesia and read the lawyer answers, or ask your own questions for free.

Can my [company removed] export machinery if the buyer is linked to a sanctioned entity?
Sanctions & Export Controls
We received a purchase order from a trading company in another country, but our bank flagged the buyer as potentially connected to a sanctioned group. I want to know what checks and documents we must do before shipping, and what penalties could apply if we get it wrong.
Lawyer answer by LAW FIRM ERIC BRYAN & PARTNERS KANTOR HUKUM DAN PENGACARA

**Conclusion:** Although Indonesia does not have a law that directly adopts international trade sanctions from other countries, your company still has to be very careful. Involvement with sanctioned parties can trigger investigations by Indonesian financial and law enforcement authorities based...

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Can my Indonesian company export machine parts if the end user may be in a sanctioned country?
Sanctions & Export Controls
We received an order for industrial spare parts, but the buyer won’t clearly disclose the final end user and destination. I’m worried we could breach sanctions or export control rules if the goods are rerouted. What checks and clauses should we put in place before shipping?
Lawyer answer by Ramanda International Consulting Firm Cab. Surabaya

Thank you for your inquiry. In principle, an Indonesian company may export machine parts; however, the situation you described raises significant sanctions and export control risks, particularly due to the lack of clarity regarding the final end user and destination....

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How a Mulyorejo export can trigger Indonesian controls

Mulyorejo is part of Surabaya, so export and sanctions matters are handled under Indonesian national rules, not a separate district licensing system. A business based there may need to check export permits, customs requirements, restricted-goods rules, and whether counterparties or payments raise sanctions concerns.

For shipments routed through Surabaya, including Tanjung Perak, customs declarations and supporting documents must match the goods and any required export approvals. Indonesia’s targeted financial sanctions obligations are distinct from US, EU, or UK sanctions, but those foreign rules may also affect a deal involving a foreign bank, buyer, currency, or other jurisdictional connection.

A lawyer can assess the goods, destination, end user, payment route, and applicable Indonesian or foreign rules before shipment or payment. If goods or funds have already been held, counsel can help identify the authority and legal basis, preserve records, and prepare a response or application for review.

When a lawyer may be useful for a Mulyorejo business

  • A shipment from a Mulyorejo office or warehouse is delayed at Tanjung Perak because the export declaration, permit, or product classification is questioned.
  • A company plans to export machinery, chemicals, electronics, or other goods that may be subject to commodity-specific restrictions or end-use checks.
  • A buyer, supplier, vessel, or beneficial owner appears on a sanctions list, or a bank asks for additional information before processing a payment.
  • A business receives a customs notice or a request from an Indonesian authority about a possible export-rule breach.
  • A company is entering a contract with a foreign counterparty and needs clauses covering restricted parties, end use, shipment holds, or termination.
  • A firm faces a foreign sanctions concern because a transaction uses a foreign bank, currency, shipping route, or business partner.

Indonesian laws that may apply

Law No. 7 of 2014 on Trade, enacted on 11 March 2014 and amended through Law No. 6 of 2023, provides the statutory framework for trade, including government controls over exports. The applicable export requirements can depend on the product and current implementing rules, so checking the latest requirements is essential.

Law No. 10 of 1995 on Customs, as amended by Law No. 17 of 2006, governs customs matters including export declarations, customs supervision, and enforcement. It is relevant when goods are examined, delayed, or investigated during clearance.

Law No. 9 of 2013 on the Prevention and Eradication of Terrorism Financing, enacted on 13 March 2013, provides for measures involving terrorism-related financing and asset restrictions, including obligations connected to designated persons and entities. A lawyer should assess whether a particular listing or asset-freeze measure applies to the client and transaction.

Frequently asked questions

Does Indonesia have the same sanctions rules as the United States or the European Union?

No. Indonesia has its own laws and obligations, including targeted financial sanctions measures, while US and EU rules are separate legal regimes. Foreign rules may still affect a transaction if it has a relevant connection to those jurisdictions or their financial systems.

Do all exports from Mulyorejo need a special permit?

No. Requirements depend on the goods, destination, and current Indonesian export rules. Check product classification and any restrictions or licensing requirements before agreeing to ship.

What should I do if Customs holds my shipment at Tanjung Perak?

Obtain the written notice or explanation, shipment records, export declaration, invoices, and permits. A lawyer can help identify the issue and prepare a timely, documented response to the relevant customs office.

Can a lawyer check whether a foreign buyer is sanctioned?

Yes. Counsel can review relevant sanctions lists and ownership or control information, then assess the transaction’s Indonesian and foreign-law connections. A name match alone may not establish that a party is restricted, so the details should be checked carefully.

Who can seek legal advice about a sanctions or export-control issue?

Individuals, exporters, importers, logistics providers, and other businesses involved in a transaction can consult an Indonesian lawyer. A lawyer can also assess whether separate foreign counsel is needed for rules outside Indonesia.

How much does a lawyer cost?

Fees depend on the work, urgency, complexity, and whether the matter involves a shipment, investigation, or cross-border advice. Ask for a written fee proposal that separates professional fees, taxes, and expected expenses.

How long does an export-control review take?

A preliminary review may be possible within days if product and transaction documents are complete. Agency decisions, permit processing, or investigations can take longer, and timing depends on the authority and the issue.

Can a lawyer guarantee that a held shipment will be released?

No. Release depends on the applicable rules, the facts, and the authority’s decision. Counsel can clarify the legal basis, correct documentation where possible, and present the client’s position, but cannot guarantee an outcome.

What documents should I bring to an initial consultation?

Bring product specifications, tariff classification if available, invoices, contracts, shipping documents, export permits, and correspondence with Customs or a bank. Include details about the destination, end user, payment route, and any party-screening results.

Is an export restriction the same as a sanctions designation?

No. An export restriction usually concerns goods, destinations, licensing, or permitted uses, while a sanctions designation may restrict dealings with a named person or entity or affect their assets. A transaction can raise both kinds of issues.

Can a lawyer help before a transaction is signed?

Yes. Early advice can identify licensing and screening issues before goods are shipped or funds are transferred. Counsel can also propose contract terms addressing compliance checks, delays, and termination rights.

Official resources

  • Ministry of Trade, Directorate General of Foreign Trade: information on trade policy, export requirements, and relevant trade services.
  • Directorate General of Customs and Excise: customs procedures, export declarations, and clearance matters; contact the office responsible for the shipment’s customs route.
  • Indonesian Financial Transaction Reports and Analysis Center (PPATK): receives and analyzes financial transaction information and supports Indonesia’s efforts to prevent money laundering and terrorism financing. It is not an export-licensing authority.

Next steps for finding and hiring a lawyer

  1. Collect the product description, proposed destination, buyer and end-user details, payment route, shipment records, and any government or bank notice. Allow a few hours to assemble the main documents.
  2. Write a short timeline of the transaction, including contract, permit, payment, and shipment dates. Note any deadline stated in an official notice.
  3. Search for Indonesian advocates who handle customs, trade regulation, export compliance, or financial sanctions matters. Ask whether they have handled the specific type of goods or issue involved.
  4. Check the advocate’s professional standing and ask who will handle the matter, including any foreign-law coordination that may be required. Arrange initial consultations promptly if a shipment or response deadline is pending.
  5. Ask for a written scope, fee estimate, expected expenses, and an initial assessment of the applicable rules and likely next steps. Compare proposals on experience and approach, not price alone.
  6. Agree on instructions and provide complete, accurate records. Confirm who will contact Customs, a bank, or another authority, and how updates and deadlines will be managed.

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The information provided on this page is for general informational purposes only and does not constitute legal advice. While we strive to ensure the accuracy and relevance of the content, legal information may change over time, and interpretations of the law can vary. You should always consult with a qualified legal professional for advice specific to your situation.

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