Legal Transparency in OJK’s Handling of Mysterious Customer Fund Losses in Indonesian Banking

Abstract

This study aims to analyze the effectiveness and transparency of the legal system in the Financial Services Authority's (OJK) handling of cases involving mysterious customer fund losses in Indonesian banking institutions. The development of digital banking technology has increased the convenience of financial transactions but has simultaneously introduced risks of cybercrime, internal access abuse, and security system weaknesses that potentially harm customers.

The research problem focuses on three main aspects: OJK's supervisory mechanisms for banking transaction activities, legal approaches to identifying bank negligence, and the forms of legal protection available to customers who experience fund losses without their consent or knowledge.

The research employs a normative legal method using statutory, conceptual, and case approaches. Analysis is conducted on banking legal provisions, consumer protection, electronic system governance, and financial services sector dispute resolution mechanisms.

The study results indicate that banking supervision has evolved toward a risk-based approach that emphasizes strengthening information technology security and internal controls. However, proving bank liability still faces obstacles in the form of information asymmetry between customers and banking institutions. Therefore, it is necessary to strengthen digital forensic transparency, implement evidentiary principles that consider the consumer's position, and improve dispute resolution and compensation mechanisms.

Keywords: Financial Services Authority, legal transparency, customer fund losses, bank liability, consumer protection, digital banking.

Abstract

This study examines the effectiveness and transparency of the legal framework governing the Financial Services Authority (OJK) in addressing cases of unexplained customer fund losses within Indonesian banking institutions. Digital banking transformation has improved the accessibility and efficiency of financial transactions while introducing significant risks associated with cybercrime, internal fraud, unauthorized transactions, and information technology vulnerabilities.

The research focuses on three principal issues: OJK's supervisory mechanisms for banking transactions, legal approaches to determining bank negligence, and legal protection available to customers who experience unauthorized financial losses.

This study employs normative legal research using statutory, conceptual, and case approaches. It examines banking regulations, consumer protection legislation, electronic system governance, and financial dispute resolution mechanisms.

The analysis indicates that banking supervision has increasingly adopted a risk-based approach emphasizing information technology security and internal controls. Nevertheless, substantial information asymmetry between banks and customers continues to complicate the determination of liability. Strengthening digital forensic transparency, developing fair evidentiary mechanisms, and improving dispute resolution and compensation procedures are therefore essential to achieving substantive consumer protection.

Keywords: Financial Services Authority, legal transparency, customer fund losses, bank liability, consumer protection, digital banking.

INTRODUCTION

Banking institutions hold a strategic position in supporting national economic development and growth. As financial intermediation institutions, banks perform the function of collecting public funds in the form of deposits and channeling them back through credit and various other financing facilities.

The sustainability of these functions depends heavily on public trust in the security and integrity of the banking system. Trust is a fundamental element in the legal relationship between banks and customers because the public entrusts the management and storage of funds to institutions that have a professional obligation to safeguard them.

In its development, advancements in information technology have driven significant changes in banking service systems. Transaction activities that previously required the customer's physical presence can now be conducted via mobile banking, internet banking, and various electronic payment services.

Digital transformation brings benefits in the form of increased efficiency, speed, and ease of transactions. However, digitalization also creates new vulnerabilities, especially regarding data security, cybercrime, and the possibility of system abuse by internal or external parties.

One issue of concern in banking sector consumer protection is the phenomenon of mysterious customer fund losses. Such events can be characterized by a decrease in account balances without any transactions known, intended, or approved by the account holder.

The causes can be related to various forms of crime, such as phishing, social engineering, ATM card cloning, digital identity theft, and abuse of authority by bank employees.

In certain conditions, fund losses can also be related to information technology weaknesses and failures in transaction security mechanisms.

Legal issues arise when banks and customers have differing views regarding the cause of the loss. The bank may state that a transaction was processed through applicable authentication procedures, while the customer asserts that the transaction was not performed or approved by them.

These differences create evidentiary problems, given that technical information regarding transactions is largely in the bank's possession. Customers generally do not have access to authentication records, system logs, or the results of digital forensic examinations.

This situation demonstrates the existence of information inequality or information asymmetry in the relationship between banking institutions and consumers.

The Financial Services Authority, as the regulator and supervisor of the financial services sector, has the responsibility to ensure the implementation of a sound banking system and to provide protection for consumer interests.

The basis for this authority is found in Law Number 21 of 2011 concerning the Financial Services Authority, as amended by Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector.

In carrying out its functions, the OJK is required to ensure that supervision is not only oriented toward administrative compliance but also pays attention to the effectiveness of risk control and the protection of customer rights.

Based on this background, this research is directed to answer three main problems.

First, what are the mechanisms and effectiveness of OJK's supervision in overseeing the security of fund movements in the national banking system?

Second, what legal investigation and evidentiary approaches can be used to identify bank negligence in cases of customer fund losses?

Third, what forms of legal protection and dispute resolution mechanisms are available to customers who are victims of mysterious fund losses?

Through this discussion, the research is expected to provide a conceptual contribution to strengthening legal transparency, banking institution accountability, and consumer protection in the implementation of digital financial services.

RESEARCH METHODS

This research uses a normative legal research method or doctrinal legal research, which is a research method that focuses on the study of legal norms, legal principles, doctrines, and legislation related to the problems being studied.

The research approach is carried out through three main approaches.

First, the statutory approach (statute approach), which is by examining legal provisions governing banking implementation, OJK authority, consumer protection, electronic systems, and financial dispute resolution mechanisms.

Second, the conceptual approach (conceptual approach), which is by examining the concepts of legal liability, banking prudential principles, information asymmetry, consumer protection, and evidentiary theory in banking disputes.

Third, the case approach (case approach), which is used to examine patterns of legal problems in customer fund loss disputes, especially those related to unauthorized transactions and alleged banking system negligence.

Primary legal materials include the Civil Code, the Banking Law, the Consumer Protection Law, the OJK Law, the Electronic Information and Transactions Law, and regulations related to banking information technology supervision and implementation.

Secondary legal materials are obtained from legal literature, academic books, and scientific studies that discuss the responsibilities of financial institutions and consumer protection mechanisms.

Analysis is conducted qualitatively by connecting applicable legal norms and problems that arise in the implementation of digital banking services.

RESULTS AND DISCUSSION

1. Characteristics of Mysterious Fund Losses in the Banking System

The development of digital banking services has created changes in the form and characteristics of financial transaction risks. Threats to the security of customer funds are no longer limited to physical theft but can occur through electronic access that is difficult to recognize directly.

To determine the form of legal liability, it is necessary to identify the cause of the fund loss.

In general, there are three main categories that can serve as a basis for analysis.

a. Internal Banking Deviations

Internal deviations occur when individuals who have an employment relationship or access to the banking system abuse their authority to perform actions that harm customers.

Such deviations can take the form of document forgery, transaction manipulation, unauthorized system access, or fund transfers not based on customer consent.

In such circumstances, legal liability needs to be analyzed based on the relationship between the perpetrator's actions, the internal control system, and the bank's obligation to control operational risks.

b. Information Technology System Weaknesses

Fund losses can also be related to vulnerabilities in information technology systems.

Forms of weakness can include application security breaches, data leaks, authentication process failures, or the non-functioning of suspicious transaction detection mechanisms.

In this context, banks are required to organize information technology systems reliably by considering applicable risk management standards.

c. External Cybercrime

External cybercrime is an unlawful act committed by parties outside the banking institution to gain access to customer information or funds.

The modes used can include phishing, social engineering, malware, SIM swaps, and authentication data theft.

Although such actions are carried out by third parties, the assessment of bank legal liability still requires an examination of the adequacy of transaction security and the possibility of negligence in risk control.

Thus, the determination of liability cannot be based solely on the identity of the perpetrator of the crime but also needs to consider the entire process and system that allowed the loss to occur.

2. Digital Forensic Audit as an Evidentiary Instrument

Evidence is a very important element in resolving customer fund loss disputes.

In electronic transactions, evidence is not only in the form of written documents but also includes electronic records that track user and system activity.

A digital forensic audit serves to obtain a picture of the process of a transaction, including the devices used, authentication mechanisms, and the possibility of access abuse.

Some of the main components that need to be examined include:

a. Authentication and Device Logs

This component records information regarding access to digital banking services.

The information analyzed can include IP addresses, device identities, access times, identifiable locations, and security verification history.

Examination of these components can help identify the use of unknown devices or access patterns that do not match the customer's normal activity.

b. Banking System Transaction Logs

Transaction records in the core banking system can be used to determine the time of transaction execution, the identity of the system user, and the processing and authorization mechanisms.

Examination of transaction logs is also important to determine whether there was any use of internal access rights that did not comply with authority.

c. Fraud Detection System

The Fraud Detection System is a risk control instrument used to recognize the characteristics of suspicious transactions.

Examination of this system aims to determine whether a transaction met certain risk parameters, whether the system provided a warning, and what follow-up was taken regarding that warning.

If the system is unable to detect activity that should have been recognized as a risky transaction, this condition can be one of the indicators that need to be analyzed in assessing the quality of the bank's security.

However, conclusions regarding negligence must still be based on the overall evidence and applicable legal standards of obligation.

3. Information Asymmetry and Proving Bank Negligence

One of the main obstacles in resolving fund loss disputes is the inequality in information control between banks and customers.

In banking legal relationships, banks have control over most of the infrastructure, technology, and transaction documentation. Meanwhile, customers generally only obtain limited information through account statements or transaction notifications.

This inequality creates difficulties when customers must prove that a transaction was not performed based on their consent.

In general, Article 1865 of the Civil Code stipulates that the party asserting a right or event is obligated to prove it.

However, the application of evidentiary principles needs to be considered in relation to the characteristics of the relationship between consumers and business actors.

Article 28 of Law Number 8 of 1999 concerning Consumer Protection regulates the burden of proof regarding the presence or absence of elements of fault in compensation lawsuits as referred to in the provisions of that law.

In banking disputes that meet the scope of consumer protection provisions, this norm can be the basis for arguments regarding the shifting of the burden of proof to the business actor.

Thus, the burden of proof should not place the entire technical obligation on customers who do not have access to the bank's electronic systems.

In addition, there is the doctrine of res ipsa loquitur, which conceptually can be considered when a loss indicates the possibility of negligence by the party controlling the related object or system.

However, the application of this doctrine in Indonesian banking disputes must still be adjusted to the provisions of evidentiary law and the concrete circumstances of each case.

The doctrine cannot be understood as a provision that automatically establishes all fund losses as the bank's fault.

What is needed is an evidentiary approach that considers the balance of the legal position of the parties and the availability of evidence that can be examined objectively.

4. Bank Legal Liability for Customer Losses

In Indonesian civil law, the relationship between a bank and a customer can give rise to legal obligations originating from agreements or statutory provisions.

If a bank does not carry out the obligations that have been agreed upon, liability can be analyzed through the concept of default (wanprestasi).

Article 1243 of the Civil Code provides the basis for regulation regarding the reimbursement of costs, losses, and interest due to the non-fulfillment of an engagement based on applicable legal requirements.

In the context of fund losses, a default lawsuit can be considered if there is a violation of the bank's contractual obligations that can be proven.

In addition, Article 1365 of the Civil Code provides a legal basis regarding unlawful acts (perbuatan melawan hukum).

Liability based on unlawful acts requires proof of the elements of an unlawful act, fault, loss, and a causal relationship.

Thus, not every fund loss automatically fulfills the elements of default or an unlawful act.

Assessment must be carried out based on facts, applicable legal provisions, the legal relationship of the parties, and the results of the examination of the cause of the loss.

5. OJK Supervision and Banking Consumer Protection

The Financial Services Authority has the authority to regulate and supervise the financial services sector based on Law Number 21 of 2011 as amended by Law Number 4 of 2023.

In its development, consumer protection is strengthened through Financial Services Authority Regulation Number 22 of 2023 concerning Consumer and Community Protection in the Financial Services Sector.

This regulation replaces POJK Number 6/POJK.07/2022 and strengthens various aspects of consumer protection, including the rights and obligations of the parties, the behavior of financial services business actors, and the implementation of consumer services.

In the implementation of banking information technology, provisions regarding risk management and system security also obtain a foundation through POJK Number 11/POJK.03/2022 concerning the Implementation of Information Technology by Commercial Banks.

This regulation is supplemented by the OJK Board of Commissioners Member Regulation Number 1 of 2026 concerning the Implementation of Information Technology by Commercial Banks.

This legal framework demonstrates the importance of information technology governance, data security, risk control, and internal audit in the implementation of banking services.

Conceptually, customer legal protection can be distinguished into two forms.

a. Preventive Legal Protection

Preventive protection is an effort to prevent losses before a dispute arises.

Its forms include the bank's obligation to implement transaction security systems, internal access control, risk management, provision of accurate information, and complaint mechanisms that can be accessed by consumers.

Preventive protection also demands continuous supervision of the development of digital security threats.

b. Repressive Legal Protection

Repressive protection is provided after a violation or loss to the customer has occurred.

Its mechanisms can take the form of complaint examination, dispute resolution, compensation based on proven liability, and administrative, civil, or criminal law enforcement in accordance with the characteristics of the violation.

The effectiveness of both forms of protection depends on the consistency of supervision and the ability of the relevant institutions to provide certainty of resolution.

6. Dispute Resolution Mechanisms for Customer Fund Losses

Customers who experience fund losses without authorization have a number of legal mechanisms to file complaints and obtain resolution.

a. Internal Complaints to the Bank

The initial stage is carried out through the submission of an official complaint to the bank where the funds are stored.

Customers need to provide the chronology of the event, relevant account identity, transaction evidence, and supporting documents.

Banks are obligated to follow up on complaints in accordance with the provisions of financial services sector consumer complaint services.

In this process, the bank needs to examine transaction records, authentication mechanisms, and the possibility of system failure or access abuse.

The results of the investigation must be the basis for determining the cause of the loss and the form of resolution that can be provided to the customer.

b. Resolution through LAPS SJK

If internal resolution does not result in an agreement, the customer can pursue an out-of-court dispute resolution mechanism through the Financial Services Sector Alternative Dispute Resolution Institution (LAPS SJK).

This institution provides dispute resolution mechanisms such as mediation and arbitration in accordance with applicable requirements and provisions.

Mediation aims to help the parties reach an agreement through the assistance of a neutral mediator.

Arbitration is an out-of-court civil dispute resolution mechanism based on an arbitration agreement that meets legal requirements.

The existence of LAPS SJK provides an alternative for consumers to resolve disputes without having to go directly through the judicial process.

c. Civil Lawsuits and Criminal Reporting

Customers can also file civil lawsuits if there is a sufficient legal basis to demand bank liability.

Lawsuits can be based on default or unlawful acts in accordance with the nature of the legal relationship and available evidence.

If indications of a criminal act are found, such as data theft, fraud, system manipulation, or abuse of authority, the event can be reported to law enforcement officials.

Criminal and civil processes have different goals and evidentiary mechanisms, so their use must be adjusted to the characteristics of the case.

7. The Position of the Deposit Insurance Corporation in Fund Loss Cases

The Deposit Insurance Corporation (LPS) has a role in the public deposit insurance system in banking institutions.

However, it is necessary to distinguish between deposit insurance mechanisms in handling failed banks and the issue of fund losses due to disputed transactions at banks that are still operating.

Deposit insurance by the LPS is carried out based on the provisions of legislation concerning deposit insurance, including in the context of business license revocation and bank handling processes.

Meanwhile, fund losses due to alleged unauthorized transactions at banks that are still conducting business activities are issues that require examination of the liability of the bank and related parties.

Therefore, deposit insurance mechanisms cannot be directly equated with the obligation to provide compensation for every electronic transaction dispute.

This distinction is important so that customers understand the scope of protection provided by each institution.

8. Comparison of Customer Protection in Indonesia, Singapore, and the UK

Strengthening banking consumer protection can be done through a comparative study of the legal systems of other countries.

Singapore and the UK are two countries that have regulatory frameworks related to electronic payment transactions and financial service user protection.

a. Consumer Protection Framework in Singapore

The Monetary Authority of Singapore (MAS) develops electronic payment user protection guidelines that regulate the responsibilities of the parties in unauthorized transactions.

Singapore also develops a Shared Responsibility Framework that regulates the division of responsibility in certain phishing fraud categories between financial institutions and telecommunications service providers.

This framework demonstrates the importance of establishing clear obligations for service provider institutions to prevent and handle risky transactions.

Singapore's experience can be study material for Indonesia in formulating the strengthening of transaction supervision and the division of proportional responsibility.

b. Consumer Protection Framework in the UK

The UK has payment service regulations that provide protection to consumers in cases of unauthorized transactions.

Through the Payment Services Regulationsframework, regulations regarding the responsibilities of payment service providers and refund mechanisms become an important part of consumer protection.

Its implementation still pays attention to provisions regarding transaction authorization, indications of fraud, and the responsibilities of service users.

This comparison shows that consumer protection requires clear mechanisms regarding evidence, investigation, and loss recovery.

For Indonesia, aspects that can be considered are strengthening investigation transparency and establishing recovery procedures that provide certainty without ignoring the principle of prudence and examination of each case.

9. Reconstruction of the Customer Legal Protection System

Based on the analysis of supervision and dispute resolution mechanisms, there are a number of aspects that need to be strengthened to increase the effectiveness of customer protection.

a. Strengthening Digital Forensic Audit Transparency

One of the recommendations of this research is the need for more detailed regulations regarding the openness of digital forensic examination results in fund loss disputes.

Customers need to obtain an adequate explanation regarding the cause of the loss, the examination process, and the basis for determining liability.

This openness can be realized through investigation reports that contain relevant information without ignoring personal data protection, third-party information confidentiality, and bank system security.

As a policy proposal, this research recommends establishing standards for the submission of examination results within a measurable timeframe, including the possibility of providing an initial report within seven working days for cases that allow for initial examination.

This recommendation is an idea for strengthening regulation, not a provision that has generally applied to all cases of customer fund loss.

b. Development of a Provisional Compensation Scheme

This research also proposes studying a temporary refund mechanism or provisional reimbursement for transactions that meet certain criteria.

In this scheme, customers suspected of experiencing unauthorized transactions can obtain temporary recovery while the investigation process is ongoing.

Its implementation requires clear requirements regarding transaction identification, risk assessment, initial evidence, potential for abuse, and the possibility of adjusting resolution results after the investigation is completed.

The proposal for a temporary refund within a maximum of 3 x 24 hours can be considered as a policy model that requires feasibility studies and a basis for further regulation.

Thus, this mechanism is not placed as a legal obligation that has applied automatically.

c. Strengthening Inter-Agency Coordination

Handling fund losses through electronic transactions often involves various parties, including the sending bank, receiving bank, supervisory institutions, and law enforcement officials.

In certain circumstances, fund tracing may also require cooperation with institutions that have authority over financial transaction analysis.

Therefore, coordination between the OJK, Bank Indonesia, law enforcement officials, and related institutions needs to be strengthened in accordance with their respective authorities.

One direction of development that can be considered is the formation of a mechanism for the exchange of information and the handling of risky transactions more quickly.

Strengthening coordination is expected to increase the effectiveness of transaction tracing and prevent the movement of funds suspected of being related to criminal acts.

CONCLUSION

Based on the results of the analysis and discussion, three main conclusions can be drawn.

First, OJK's supervision of banking implementation has evolved toward a risk-based approach that emphasizes the importance of governance, internal control, and information technology security.

Nevertheless, the development of cybercrime and the complexity of electronic transactions demand more adaptive supervision. The effectiveness of supervision is not sufficiently measured based on the existence of regulations, but must also pay attention to the bank's ability to prevent, detect, and handle transactions that potentially harm customers.

Second, proving bank negligence in cases of mysterious fund losses requires objective examination through digital forensic audits.

Examination of authentication logs, transaction records, and fraud detection systems are important instruments for knowing the cause of the loss.

In the legal aspect, evidentiary principles need to be applied by considering the inequality of information access between banks and customers.

The use of arguments regarding the shifting of the burden of proof and the doctrine of res ipsa loquitur can be part of the study of strengthening consumer protection, as long as their application is in accordance with applicable legal norms.

Third, customer legal protection already has a basis in legislation concerning banking, OJK, consumer protection, and electronic systems and transactions.

Resolution mechanisms can be carried out through internal complaints, out-of-court dispute resolution, or judicial channels.

However, the certainty of protection still requires strengthening in aspects of investigation transparency, information access, effectiveness of dispute resolution, and loss recovery mechanisms.

Thus, legal protection for customers who experience mysterious fund losses needs to be developed through an approach that integrates legal certainty, technological progress, and a balance of responsibility between banking institutions and consumers.

SUGGESTIONS

Based on the research results, there are several recommendations that can be considered.

1. For the Financial Services Authority

The OJK is expected to strengthen supervision of digital banking transaction security and develop clearer standards regarding the transparency of examinations of alleged customer fund losses.

Regulations regarding the submission of investigation results and loss recovery mechanisms also need to be studied so that they can provide better legal certainty.

2. For Banking Institutions

Banking institutions need to improve the quality of information technology security, the effectiveness of the Fraud Detection System, and supervision of internal access.

In addition, banks must ensure that complaint handling mechanisms are carried out professionally, objectively, and transparently in accordance with applicable provisions.

3. For Customers and the Public

Customers are expected to increase their understanding of digital transaction security, maintain the confidentiality of authentication data, and immediately report suspicious account activity.

Understanding consumer rights and dispute resolution mechanisms is also an important part of increasing the public's ability to obtain legal protection.

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