“Follow the money approach” in Indonesia anti-corruption and asset forfeiture: A comparative insight from Malaysia, Singapore, and Thailand

Abstract

The persistence of corruption and money laundering (ML) poses systemic threats to governance, economic development, and democratic legitimacy. Conventional enforcement paradigms that pursue perpetrators (“follow the suspect”) often fail to secure restitution of stolen state assets, particularly in grand corruption cases where proceeds are layered through sophisticated financial channels. The “follow the money” approach, endorsed by the United Nations Convention against Corruption (UNCAC) and the Financial Action Task Force (FATF), reframes enforcement around asset-centric tracing, freezing, confiscation, and recovery. This article expands the discourse on the integration of “follow the money” in Indonesia’s anti-corruption framework and situates it within comparative practices in Malaysia, Singapore, and Thailand. Drawing on doctrinal analysis, FATF mutual evaluation reports, Stolen Asset Recovery (StAR) guidance, and selected case studies including Indonesia’s Wa Ode Nurhayati, Gayus Tambunan, and Jiwasraya scandals; Malaysia’s 1MDB recovery; Singapore’s CPIB-led prosecutions; and Thailand’s evolving anti-money laundering reforms the paper argues that institutionalizing asset-centric investigations and non-conviction-based (NCB) confiscation mechanisms can substantially enhance restitution of public wealth. The analysis demonstrates how financial intelligence units (FIUs), beneficial ownership transparency, cross-border cooperation, and unexplained wealth regimes have improved outcomes in comparator states, and outlines a policy roadmap for Indonesia. By integrating these lessons, Indonesia can strengthen both deterrence and asset recovery, ensuring that anti-corruption efforts serve not only punitive justice but also economic restoration.