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FTW Law Firm, Bali
Ubud, Indonesia

Founded in 2000
English
FTW Law Firm is an established commercial law practice in Bali that was set up as a partnership of legal consultants in 2000. The firm focuses on serving clients involved in Indonesian business activities with lawyers who are positioned to work across corporate matters and litigation needs.FTW Law...
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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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1 answer •
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 a Ubud transaction needs sanctions and export-control review

Ubud is in Gianyar, Bali, but sanctions and export rules are set mainly at national and international levels. A business in Ubud may need to check counterparties, goods, destinations, payment routes, and permits before importing or exporting.

This can matter to Ubud-based hotels, restaurants, galleries, craft businesses, and other traders dealing with overseas suppliers or buyers. Export declarations and customs checks are handled through Indonesia’s customs system, not through a separate Ubud sanctions office.

Indonesia’s rules include restrictions connected to terrorism financing, customs requirements, and controls on particular goods. Foreign sanctions may also affect a transaction through a foreign bank, buyer, supplier, or shipping route, even where Indonesian law does not impose the same restriction.

A lawyer can help identify which rules apply, check the transaction and goods, and coordinate with customs or licensing authorities. For a matter involving foreign sanctions, advice from counsel in the relevant country may also be needed.

Situations where legal advice can help

  • A Ubud craft or art exporter receives an order from an overseas buyer, but the buyer, beneficial owner, or payment bank raises a sanctions concern.
  • A hotel, restaurant, or wellness business plans to import equipment and needs to check whether the goods require permits or face import restrictions.
  • A shipment of goods sold by a Ubud business is held for customs review, or its export declaration or supporting documents are questioned.
  • A local company receives an investment or payment from a person or entity that may appear on an Indonesian terrorism-financing list or a foreign sanctions list.
  • A foreign bank delays or rejects a payment connected to a Ubud transaction, and the business needs to understand the stated reason and available options.
  • A business is considering a new overseas supplier, buyer, or shipping route and wants to assess sanctions and export-control risks before signing or paying.

Indonesian laws and rules that may apply

Law No. 9 of 2013 on the Prevention and Eradication of Terrorism Financing provides Indonesia’s framework for measures against terrorism financing, including freezing assets in relevant cases. Its application depends on the facts and the applicable designation and procedures.

Law No. 7 of 2014 on Trade governs trade activities, including export and import controls. It was among the laws amended through the Job Creation legislation, most recently enacted as Law No. 6 of 2023.

Law No. 10 of 1995 on Customs, as amended by Law No. 17 of 2006, sets customs rules relevant to declarations, clearance, and enforcement. The Ministry of Trade and customs authorities also issue implementing rules for particular goods, licences, and restrictions, so the current requirements should be checked for each shipment.

Frequently asked questions

Does Indonesia have a separate sanctions regime for Ubud?

No. Ubud businesses are subject to Indonesian national laws and applicable international obligations, not a separate local sanctions code. Local location may affect practical contact with authorities, but it does not change the national rules.

Do foreign sanctions automatically apply to an Indonesian business?

Not necessarily. Whether a foreign measure applies depends on its jurisdictional reach and the transaction’s links to that country, such as a bank, currency, person, or shipping route. A foreign counterparty may also refuse a transaction to comply with its own rules.

What should I check before paying an overseas supplier?

Check the supplier and its ownership, the goods, destination, intermediaries, and payment route. Screening should consider relevant Indonesian restrictions and any foreign rules that may affect the transaction.

Do all exported goods from Ubud need a special licence?

No single answer applies to every product. Export declarations and supporting documents are required as applicable, while additional permits or restrictions depend on the goods and current trade rules.

What happens if customs holds an export shipment?

Ask for the reason for the hold and identify any missing declaration, permit, or supporting document. A lawyer can review the notice, communicate with the relevant customs office, and advise on a response or correction.

Can a bank freeze or reject a payment linked to a sanctioned party?

A bank may restrict or delay a payment under applicable law or its compliance obligations. Request the bank’s stated reason and preserve transaction records before deciding whether the payment can lawfully proceed or be challenged.

Can a business check Indonesian terrorism-financing designations?

PPATK publishes information relevant to Indonesia’s terrorism-financing framework, including the list of suspected terrorists and terrorist organizations. A lawyer can help confirm whether a match is reliable and what legal steps may follow.

How much does a lawyer cost?

There is no single nationwide fee for this type of advice. Fees depend on the work, urgency, and whether customs or foreign-law issues are involved, so request a written scope and fee arrangement before work begins.

How long does a sanctions or export-control review take?

A straightforward screening review may take a few business days once complete transaction documents are available. A customs hold, unclear ownership, licensing issue, or foreign-law question can take longer.

Can a foreign-owned business or foreign national get legal advice in Bali?

Yes. A business or individual involved in a transaction connected to Indonesia can seek advice from an Indonesian advocate. A matter that also engages another country’s sanctions laws may require advice from counsel qualified there.

How do I choose a suitable lawyer?

Look for an Indonesian advocate with relevant trade, customs, or financial-crime experience and ask about similar matters. Confirm who will handle the work, which jurisdictions are covered, likely timelines, and fees in writing.

Official resources

  • Directorate General of Customs and Excise handles customs administration and enforcement, including export declarations and clearance. Its Bali regional office can direct enquiries to the appropriate customs unit.
  • Ministry of Trade administers trade policy and publishes rules and licensing information for regulated imports and exports.
  • Financial Transaction Reports and Analysis Center (PPATK) is Indonesia’s financial intelligence unit and provides information relevant to terrorism-financing controls and designated lists.

Next steps

  1. Gather the proposed contract, invoices, product descriptions, shipping details, payment instructions, and ownership information for the parties. Allow one or two days to collect records.
  2. Write down the countries, banks, currencies, intermediaries, and destinations connected to the transaction. Include any customs hold notice or licensing correspondence.
  3. Identify Indonesian and foreign sanctions or trade-control issues that may be relevant. Do this before signing, shipping, or making a payment where possible.
  4. Contact an Indonesian advocate with trade, customs, or financial-crime experience. Ask whether foreign counsel is needed for any overseas sanctions exposure.
  5. Request a written scope covering screening, legal analysis, agency contact, and any foreign-law coordination. Compare fees and expected timing before instructing counsel.
  6. Ask the lawyer to confirm applicable permits, declaration requirements, and any steps needed to address a blocked payment or detained shipment.
  7. Keep a record of the advice, screening results, permits, and transaction decisions, and update the review if the buyer, goods, route, or payment method changes.

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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.