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Founded in 2020
English
Notaris, PPAT, NPAK - Kadek Oka Widiantara, S.H., M.Kn. operates as a dedicated notary public, PPAT and NPAK practice serving clients in Bali, with a focus on accuracy and reliability in legal documentation. The firm was established in January 2020 and offers notarial and PPAT services,...
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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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When trade sanctions or export-control advice matters in Tabanan

Businesses in Tabanan that sell agricultural products, food, crafts, or other goods overseas may need to check export restrictions, permits, customs requirements, and the parties involved in a transaction. Shipments may pass through Bali’s designated ports or airports, so clearance and logistics questions can involve authorities outside Tabanan.

Indonesian rules can restrict particular goods or transactions, while foreign sanctions may also affect a deal through overseas buyers, banks, currencies, or shipping providers. A lawyer can help identify which rules apply before goods are shipped or payments are made, and advise on responses to a customs hold or a blocked payment.

Situations where a lawyer may be useful

  • A Tabanan producer is preparing to export coffee, cocoa, food products, or handicrafts and needs to check whether the goods require an export permit or are subject to a restriction.
  • A customs or logistics provider reports that an export shipment routed through Bali is being held, questioned, or refused clearance.
  • A bank delays or rejects payment because a buyer, intermediary, vessel, or other party appears on a sanctions screening list.
  • A business is asked to supply machinery, technical data, or other goods that could have both civilian and military uses, and needs to assess licensing or end-use requirements.
  • A company discovers that a supplier or customer has links to a person or organisation subject to a United Nations measure or an overseas sanctions designation.
  • An exporter needs to respond to a government inquiry, provide transaction records, or challenge an administrative decision concerning restricted goods.

Indonesian rules to check

Law No. 7 of 2014 on Trade establishes Indonesia’s trade framework, including controls and requirements affecting exports. It was amended by Law No. 6 of 2023, which took effect on March 31, 2023.

Government Regulation No. 29 of 2021 on the Implementation of the Trade Sector sets out implementing rules for trade, including provisions relevant to export activities. Its requirements should be read alongside current ministerial rules and any applicable goods-specific restrictions.

Law No. 9 of 2013 on the Prevention and Eradication of the Crime of Terrorism Financing provides for targeted financial measures connected with terrorism financing, including action relating to relevant United Nations Security Council lists. It does not make every foreign economic-sanctions designation an Indonesian prohibition.

Frequently asked questions

What does trade sanctions and export-control compliance cover?

It involves checking whether goods, parties, payments, destinations, or end uses are restricted under applicable Indonesian rules. It can also include assessing foreign sanctions exposure where overseas banks, buyers, carriers, or contracts connect the transaction to another jurisdiction.

Are foreign sanctions automatically enforceable in Indonesia?

Not every foreign designation automatically creates an Indonesian legal prohibition. However, it may still affect a transaction through a foreign bank, contract, shipping provider, or another country’s laws, so the specific connections should be reviewed.

Do ordinary agricultural exports from Tabanan need a lawyer?

Not necessarily. A lawyer may be worthwhile if the product is restricted, a permit requirement is unclear, a buyer or payment route raises sanctions concerns, or customs has questioned the shipment.

Where are export questions handled for a Tabanan business?

The relevant process depends on the goods, shipment route, and customs point used. A Tabanan exporter may need to coordinate with its freight provider and the competent customs office serving the designated port or airport, as well as with the Ministry of Trade where trade permits or restrictions are involved.

What should I do if customs holds my shipment?

Ask for the written notice or stated reason, preserve the export declaration, invoices, permits, shipping records, and communications, and note any response deadline. A lawyer can assess the issue and prepare a response, but should not advise moving or reshipping goods to evade a restriction.

Can a lawyer check a buyer or supplier against sanctions lists?

Yes. A review can identify possible name matches, ownership or control concerns, and relevant transaction links, while distinguishing a confirmed match from a false positive. Screening should be repeated when parties or transaction details change.

How much does a lawyer cost in Tabanan?

Fees depend on whether the work is a document review, a permit or classification analysis, negotiations with a bank, or a response to an investigation. Ask for a written scope and fee basis, including any separate charges for translations, travel, or specialist technical advice.

How long does a compliance review take?

A review of a straightforward transaction may take days, while unclear product classifications, multiple jurisdictions, or an active customs inquiry can take longer. Timing also depends on how quickly the client, bank, freight provider, or authority supplies relevant records.

Can an individual as well as a company seek advice?

Yes. An exporter, director, employee, or other person affected by a transaction or inquiry may seek legal advice. The lawyer will need to confirm who the client is and whether the matter involves personal or company interests.

Is an Indonesian export permit the same as a foreign import licence?

No. Indonesian export requirements govern the shipment leaving Indonesia, while the destination country may impose separate import permits, product standards, or sanctions restrictions. Both sides may need checking before the parties commit to delivery.

What documents should I bring to an initial meeting?

Bring product descriptions and technical specifications, contracts, invoices, permits, export or customs records, payment messages, and any official notice. Include details of intermediaries, destination, end user, and intended use if available.

Official resources

  • Ministry of Trade of the Republic of Indonesia: Its Directorate General of Foreign Trade handles trade policy and export-related requirements. It is a useful source for checking applicable trade rules and permit processes.
  • Directorate General of Customs and Excise, Ministry of Finance: Customs officials administer export declarations, clearance, and customs enforcement at designated customs offices serving shipment routes used by Bali businesses.
  • Indonesian Financial Transaction Reports and Analysis Center (PPATK): PPATK supports Indonesia’s efforts to prevent and address money laundering and terrorism financing, including relevant financial intelligence and targeted financial measures.

Steps to find and hire a lawyer

  1. Define the issue. Write down the product, destination, parties, payment route, shipment status, and any deadline. Allow a day to gather the basic facts.
  2. Collect records. Assemble contracts, invoices, technical descriptions, permits, customs documents, bank notices, and correspondence before contacting lawyers.
  3. Shortlist Indonesian advocates. Look for lawyers who can explain experience with trade regulation, customs, financial restrictions, and cross-border transactions relevant to your issue.
  4. Ask about conflicts and scope. In an initial consultation, confirm the lawyer can act for you and identify whether the work covers classification, permits, bank screening, customs engagement, or an appeal.
  5. Confirm fees and timing in writing. Request the expected deliverables, fee basis, likely timetable, and any additional costs before authorising work.
  6. Agree on immediate safeguards. Ask what to do with pending payments or shipments while the review is underway, and follow any lawful instructions from customs or your bank.

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Disclaimer:

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.

We disclaim all liability for actions taken or not taken based on the content of this page. If you believe any information is incorrect or outdated, please contact us, and we will review and update it where appropriate.