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Conceptual Article

Application of Universal Jurisdiction Principles to Cross-Country Money Laundering

ABSTRACT
The fight against transnational crimes, particularly involving cross-border money laundering, requires a
shift from a territorial to a universal jurisdiction approach. The aim of this investigation was to explore
the practicality of universal jurisdiction principles in combating cross-border money laundering, which
eludes effective criminal law mechanisms to arrest and prosecute offenders. Findings revealed that the
crime of cross-border money laundering has not been considered one of the delicta juris gentium or
international crimes, leading to an increase in the number of perpetrators who enjoyed refuge in various
countries. Therefore, a universal jurisdiction approach is necessary to ensure that criminals are not
immune to prosecution, and justice is served universally. As a result, every state must fulfill its
obligation of arresting and prosecuting offenders wherever they may be found to uphold the law and
universal justice. In conclusion, the need for a universal jurisdiction approach is crucial to combat the
increasing threat of transnational crimes, particularly in the context of cross-border money laundering.

Keywords: money laundering; transnational crime; universal jurisdiction; impunity .

A. INTRODUCTION It is imperative to enhance the process of


Globalization is a critical modern stage in criminalizing transnational criminal activities in
societal development, which is essential to order to foster system development. As parts of
consider when investigating various aspects of a international crime, transnational offenses
country's political, social, economic, or spiritual possess formal characteristics that are national in
facets. The integration of different areas, such as nature because they involve forbidden actions
economy, politics, law, and social relations, that that are punishable by national law. Crimes are
take place within globalization have both positive recognized as such and culprits are put on trial
and negative impacts. One negative consequence and penalized by a particular country. Therefore,
is the internationalization of crime in which the in the course of transnational crimes becoming
structure and content of criminal activities are criminalized, national laws converge due to the
influenced by the priorities of entities involved in impact of international law norms. As such,
countering crime. In recent years, there has been national legislation is solely capable of
an increasing focus on the joint efforts to combat criminalizing a conduct that does not meet the
transnational crimes that pose a significant threat requirements of international criminal
to public safety and affect the interests of multiple responsibility and is not subject to international
nations (Popko, 2021). criminal jurisdiction.
Cross-border money laundering is a form of technology. As a result, it is no surprise that
transnational crime that has emerged as a major money laundering has reached the same level as
global peril, posing a severe challenge to the high-tech crimes (EUROPOL High Tech Crime
stability of the global financial system and Centre, 2007; Bassiouni, 1974, Clark, 2004;
international economy. Its impact on human life Hoefnagels, 2013).
and civilization is profound, and it would not be an Indonesia, akin to Ukraine, has
overstatement to categorize it as a foe of encountered the distribution of unlawful money
humanity, an enemy of all people ( hostis humani laundering valued at 600 billion dollars in the past
generis) (Burgess Jr, 2005; Chuasanga, & decade. The global extent of expenses incurred
Victoria, 2019). due to cross-national money laundering has
Transnational money laundering crimes are tallied at 2-5% of the Gross Domestic Product
perpetrated through various jurisdictions with the (GDP) (Budiantoro, 2016; Sarigul, 2013; Nazar,
offenders diverging in nationality and originating Raheman, & ul Haq, 2023; Beebeejaun, & Dulloo,
from multiple countries. Organized crime rings 2023). Indonesian fugitives have stashed corrupt
carry out such activities across the globe with the proceeds amounting to IDR 600 trillion in
anonymity of perpetrators and victims rendering Singapore (Atmasasmita, 2004). The evidence
their impact and damage potential to the global indicates an annual rise in both the severity and
financial system in limitless and indiscriminate damages resulting from money laundering
ways. These criminal activities may occur in any offenses.
country without exception. Money laundering Money laundering has become a universal
offenses are usually orchestrated in an organized issue that demands nations to collaborate and
fashion across multiple regions around the globe. find international remedies. The creation of the
It is possible to conduct money laundering from Financial Action Task Force (FATF) aims to
any location, with no knowledge of the enhance collective efforts among countries
wrongdoers or victims' whereabouts, as well as through global coordination to eliminate money
the extent of the harm they inflict on the laundering offenses globally (Mekpor, Aboagye,
worldwide financial system. Any country could be Welbeck, 2018; Pavlidis, 2021; Nance, 2018). In
affected in this way (Le Nguyen, 2020; Amrani, & the past, several international agreements were
Ali, 2021). organized as collaborative efforts between
The evolution of financial technology and different countries to address money laundering
banking systems has played a critical role in the worldwide. These included conventions, such as
growth of money laundering crimes. These crimes the 1988 Vienna Convention, the 1990
have become increasingly complex and Strasbourg Convention, the 2000 Palermo
sophisticated, aligning with the advancements in Convention, the 2006 United Nations Convention
on Transnational Crime, and the 2003 United (Le Nguyen, 2020; Sultan, & Mohamed, 2022;
Nations Convention on Anti-Corruption. Despite Menon, & Siew, 2012). Consequently, a novel
efforts to combat it, cross-border money approach is necessary to combat international
laundering remains a challenge, particularly with money laundering activities by transnational
apprehending those responsible. Evidence of this perpetrators through the implementation of the
is found in the significant number of money universal jurisdiction concept within law
launderers who remain at large in different enforcement strategies (Nurdin, & Turdiev, 2021).
nations, benefiting from the protection of safe Transnational money laundering criminals
havens. These actors may perpetrate their can exploit legal gaps to evade punishment by
actions with ease and quickly flee to different crossing borders or operating in multiple
regions without consequence (Bassiouni, 1997; jurisdictions, putting victims in any country at risk.
Wangga, Wirawan, & Kardono, 2022). To prevent impunity, a universal approach to
The variance in legal systems between the jurisdiction is necessary, requiring all sovereign
country where the offender is seeking refuge and countries to expeditiously prosecute perpetrators
the country where the unlawful act is first wherever they may be hiding. This upholds the
committed may also play a role in the lack of universal value of justice, which demands that all
accountability for the perpetrators. This may have offenders be held accountable for their crimes
consequences on how the principle of "double and that no one is exempt from punishment.
criminality" is interpreted as the legal framework Therefore, it is the responsibility of every
of another country may not acknowledge an independent nation to apprehend and bring to trial
offense as a crime. Moreover, the lack of a individuals involved in cross-border money
globally accepted and enforced international laundering schemes, regardless of their location
criminal justice system does not only worsens the or attempt to evade justice. This is in line with the
issue but also enhances the prevalence of law fundamental principle of fairness, which stipulates
enforcement against wrongdoers (Bingham, 2011; that all offenders must face the consequences of
Popko, 2019). Therefore, there is a necessity for their actions, leaving no room for impunity.
a global justice system that can be upheld This paper applied a conceptual approach
worldwide to address transnational money centered on the evolution of money laundering, a
launderers. Conversely, the lack of extradition menacing worldwide phenomenon. The study
agreements and inadequate cooperation among relied on a criminal jurisdiction-based theory
law enforcement agencies, influenced by political (Boister, 2018; Maculan, & Gil, 2020). The study
interests of different competitive nations, may used a comparative method. The results
result in incongruities and ineffective demonstrated that, by implementing universal
implementation of laws against these criminals jurisdiction, nations can apprehend and try
individuals responsible for transnational money outlined instrumentalities, compliance, policies,
laundering crimes irrespective of the location of and control in combatting money laundering.
the crime, perpetrator's nationality, or legal Moreover, previous studies emphasized on the
system in place. This approach eliminates any legal aspect of anti-laundering control (Hülsse, &
impunity that may have been present beforehand. Kerwer, 2007; Kemal, 2014; Masciandaro, 1999;
The study aimed to evaluate the suitability of Ofoeda et al., 2022; Zavoli, & King, 2021).
universal jurisdiction as a means to establish a Moreover, Yasaka (2017) suggests the need for a
comprehensive and global strategy to enforce harmonization of laws and regulations to facilitate
laws against all instances of money laundering in cooperation between jurisdictions, particularly in
diverse legal frameworks. terms of mutual legal assistance. Additionally,
Universal jurisdiction is a principle that Mugarura (2011) highlighted the importance of
allows states to exercise jurisdiction over certain establishing effective international cooperation
crimes committed outside their territory by mechanisms to ensure the success of anti-money
foreigners who do not have any connection to the laundering control. However, there is a few that
state except for the crime committed. This emphasized on the universal jurisdiction applied
principle has been applied to many transnational to money laundering control. Hence, this article is
crimes, including money laundering. There has of different point of view with previous ones in
been an increasing interest in the use of universal examining the need for robust legal frameworks
jurisdiction to combat money laundering across and resources to support the prosecution of
borders, given the transnational nature of the cross-border money laundering cases in universal
crime. The application of universal jurisdiction has jurisdiction context. This article also suggests that
the potential to allow jurisdictions to prosecute universal jurisdiction has the potential to be a
individuals or entities beyond their borders, valuable tool in the fight against cross-country
increasing the chances of bringing criminals to money laundering. Lastly, this paper emphasized
justice. on some important determinants of successful
In recent years, there have been several application of universal jurisdiction applied to
research articles discussing the feasibility and money laundering control in terms of legal,
challenges of using universal jurisdiction to practical, and political challenges.
combat cross-country money laundering. Shehu The article's state of the art lies in its
(2012) discussed financial inclusion for effective application of the universal jurisdiction principle to
anti-money laundering to counter financing of cross-country money laundering activities. The
terrorism. Ahmed (2017) examined the disparity principle of universal jurisdiction is a legal theory
among anti-money laundering methods in that permits any country to prosecute individuals
Bangladesh, while Zafarullah, & Haque (2023) for crimes that are committed outside their
borders, such as crimes against humanity or jurisdiction represents a state's jurisdictional
piracy. Applying this principle to money authority to enforce specific legal statutes against
laundering would enable countries to prosecute persons and property through the measures of
individuals who engage in cross-border money prescription and enforcement, namely, the ability
laundering activities, thereby providing national to detain and charge suspects, as well as to try
and international law enforcement agencies with a individuals for criminal acts (Akhavan, 2013;
new tool to combat global money laundering. The Barkow, 2011).
article's contribution to the field is significant in its Various categories can be used to
examination of how the principle of universal categorize jurisdiction, such as state's jurisdiction,
jurisdiction could be applied to money laundering. which includes (Lowe, & Staker, 2010):
It offers valuable insights into the legal hurdles 1. Base of Jurisdiction:
and jurisdictional challenges faced by law a. Territorial principle;
enforcement agencies when prosecuting cross- b. Personal principle;
border money laundering cases. It also provides c. Protective principle;
recommendations for policymakers and legal d. Universality principle.
practitioners on how to structure legal frameworks 2. Types of Jurisdiction:
that would enable the principle of universal a. Jurisdiction to prescribe;
jurisdiction to be effectively used in prosecuting b. jurisdiction to adjudicate;
cross-border money laundering cases. c. enforcement jurisdiction.
3. Extra-territorial exercises of jurisdiction:
B. DISCUSSIONS jurisdiction over military personnel abroad.
Legal Considerations of Universal Jurisdiction a. asserting jurisdiction over citizens or
The concept of universal jurisdiction is businesses operating in foreign countries;
inextricably linked to a state's ability to apprehend b. prosecuting individuals for crimes committed
and prosecute offenders who operate across outside of its territory;
borders. The power to bring criminals to justice is c. asserting jurisdiction over certain types of
an aspect of criminal jurisdiction that is closely crimes (such as terrorism or cybercrime) that
tied to a nation's sovereignty (Sasmito, 2017). may have international implications.
This definition of jurisdiction aligns with that of Exercise of extra-territorial jurisdiction
Lowe and Staker (2010), who describe it as the refers to the power of a country or state to
legal competence of a state or other entity, such regulate the activities or behavior of individuals or
as the European Community, to establish, entities beyond its territorial boundaries (Sekati,
implement, and enforce codes of conduct directed 2022). Extra-territorial jurisdiction allows a country
at individuals. More specifically, criminal to punish individuals or companies for the
offenses committed outside its jurisdiction when approval. Although it is a moral obligation for all
the violation has an impact or effect within its countries to apprehend transnational fugitives, the
jurisdiction. Schmidt (2022) noted that extra- transfer to the requesting state cannot happen
territorial jurisdiction can be controversial because without a formal extradition request through the
it can be seen as a violation of the sovereignty of application of enforcement jurisdiction. This
other countries. However, in situations in which approach is necessary to facilitate the proper
there is a need to enforce global standards or to legal process of extradition.
prevent harm to citizens, extraterritorial When considering the attributes of
jurisdiction can be an important tool for transnational criminal activities, universal
governments to ensure accountability (Popović, jurisdiction is not applied solely based on the
2021). gravity of the offense, but rather on the influence
The definitions for jurisdiction within the it exerts on the worldwide financial system and
various categories vary in meaning and global economy, as well as its cross-border reach.
emphasis. Nonetheless, territorial, personal (both Piracy, despite not being inherently violent, is
active and passive), and universal jurisdictions deemed a transgression of international law
are the standard and traditional definitions for (delicta juris gentium) due to the fact that pirates
jurisdiction (Arajärvi, 2011; Van Der Wilt, 2011). are able to roam freely on open waters and to
The type of jurisdiction studied in this research is evade legal jurisdiction (Lowe, & Staker, 2010).
a combination of universal and enforcement This form of money laundering, which transcends
jurisdictions, which is one among several different national boundaries, has a significant negative
types of jurisdictions that exist (Stessens, 2000). effect on the worldwide financial system, with the
This study focused on a particular type of international community viewed as a target of this
jurisdiction; the combination of universal and illicit activity. Transnational money laundering can
enforcement jurisdictions. This represents a be regarded as a violation of universally
country's actual authority, and it means that in esteemed principles of humanity and impartial
order for a fugitive to be returned to the country, justice (Popa, 2012; Simmons, Lloyd, & Stewart,
an extradition process must take place (Lowe, & 2018). Hence, a strategy that combines
Staker, 2010). The process involves executing enforcement jurisdiction with universal jurisdiction
enforcement jurisdiction, which abide by the can be employed by law enforcement officials to
fundamental principle that a country's rule of law combat transnational money laundering
cannot be enforced in another country's territory perpetrators (Arnone, & Borlini, 2010; Teichmann,
without its consent. That is to say, when a country 2020). The ultimate aim is to ensure that no
seeks to assert its jurisdiction beyond its territorial wrongdoer evades legal repercussions,
boundaries, it must first obtain the other country's
irrespective of their whereabouts and the legal enforcers to pursue legal action against those
framework implemented in each country. responsible for it.
Similar to the criminal law of Indonesia, The concept of territorial jurisdiction
Ukrainian law also implements the concept of pertains to a state's ability to apply legal statutes
active personal jurisdiction, which implies that any to its citizens, non-native individuals, and objects
offender who has fled from either country's that exist within its geographical limits. The
jurisdiction can be apprehended or subjected to principle of jurisdiction pertains to the concept of
legal proceedings under Indonesian law, state sovereignty as it empowers the state to
irrespective of the offender's location. establish and enforce laws within its territorial
Alternatively, the criminal justice systems in these boundaries for the common good. This includes
jurisdictions also utilize a form of passive personal obliging foreign nationals to abide by the laws that
jurisdiction that involves asserting the authority of are in effect within the specific country (Hovell,
a country in order to safeguard its citizens from 2018). The definition of territories extends beyond
the actions of foreign entities, regardless of their land areas, encompassing sea areas within 12
location. miles from the coast and airspace above land
The protective principle in international law boundaries. However, this definition can extend
refers to the application of jurisdiction to other up to 200 miles from the coastline within the
countries based on safeguarding the interests of Exclusive Economic Zone (EEZ) (Lowe, & Staker,
the protected state, as well as its national and 2010).
legal interests (Langer, 2011; Colangelo, 2013). As transnational crime becomes more
An instance of this is when a country counterfeits prominent, the territorial jurisdiction evolves to
the foreign currency of another country within its include both objective and subjective principles.
jurisdiction, allowing that country to exert its The concept of objective territoriality pertains to
criminal authority on the offenders outside its the territorial jurisdiction which can be exerted
borders. An additional example pertains to the over a non-native individual who perpetrates an
issue of substance misuse in a foreign nation, offense within his own nation, yet the
which has the potential to negatively impact the repercussions of the offense have a bearing on
well-being of residents living in close proximity. other nations. The nation in which the offense is
Drug abuse has a detrimental impact on the host initially committed and in which its consequences
nation, and prosecuting those responsible is are felt has an equivalent right to bring charges
deemed necessary to safeguard its citizens from against the offender. Subjective territorial
drug-related harm. The desire to safeguard jurisdiction dictates that a person, who
citizens from drug misuse motivates illegal drug perpetrates a crime within the boundaries of a
country but employs the gains from said crime to
orchestrate another crime in a foreign country, is Prosecutor Joan Garce in 1996 (Amnesty
subject to jurisdiction by the country where the International, 2013).
original crime occurred. This country reserves the It is necessary to merge the principle of
right to carry out prosecution of the offender. universal jurisdiction with the principle of
Universal Jurisdiction and State’s Enforcement enforcement jurisdiction (Stessens, 2000; Garrod,
Jurisdiction 2019). In order to effectively combat transnational
As previously discussed, universal crimes and accommodate the rising number of
jurisdiction refers to a state's ability to enforce international agreements regarding the transfer of
laws against individuals who commit the acts that criminal proceedings, the merging of the principle
breach international law due to their impact on of universal jurisdiction and enforcement
humanity as a whole (Scharf, 2012; Kontorovich, jurisdiction is imperative (Stessens, 2000; Garrod,
& Art, 2010; Reeves, 2017). A fundamental factor 2019). The latter is a relatively new form of
to take into account regarding the implementation jurisdiction, encompassing original, subsidiary,
of universal jurisdiction is that certain legal and derivative jurisdictions, that has gained
occurrences that are not encompassed by other momentum in recent times (Stessens, 2000;
jurisdictions cannot be separated from the Assalmani, 2021). This form of enforcement
purview of the law (Farmer, 2013; Hovell, 2018; jurisdiction, previously described, indicates that
Langer, 2011). The introduction of universal the country where a crime is initially carried out
jurisdiction is a significant advancement towards holds the power to prosecute the offenders.
dismantling the barriers of immunity for individuals However, other nations also possess the right to
committing international crimes across the globe do so upon receiving a request from the foreign
(Coombes, 2011; Moffett, 2015; Krings, 2012). country regarding the offender. The initiation of
The usage of universal jurisdiction is "enforcement jurisdiction" occurs when foreign
restricted to specific nations, such as Belgium, nations make requests for court proceedings. The
which implemented the concept of universal scope of enforcement jurisdiction is
jurisdiction within its constitution and domestic interconnected with the determinations made by
legislation in 1993 (Human Rights Watch, 2003; foreign courts concerning the extradition of an
Langer, 2011; Panáková, 2011). The utilization of individual in their jurisdiction (Stessens, 2000).
universal jurisdiction was exemplified in the Enforcement jurisdiction extends beyond the legal
apprehension of General Augusto Pinochet, who proceedings concerning evidence exchange and
served as the Regent of the Chilean Military encompasses the extradition process entailing the
Junta, apprehended in England during 1988. This surrender of individuals or wrongdoers (Lowe, &
was carried out under the charge of genocide, Staker, 2010).
based on an arrest warrant issued by Spanish
A fundamental tenet of the enforcement culprits anywhere they are found is important, it
jurisdiction is that the authority of an overseas must be balanced against enforcement
nation cannot be exercised within the borders of a jurisdictions that adhere to treaty-based
separate nation without said nation's jurisdictions. It is imperative to do so as the
authorization. When a nation desires to expand its principle of universal jurisdiction is not
territorial jurisdiction beyond its current limitations, fundamentally predicated upon or interdependent
it must collaborate and obtain consent from other upon the cooperation amongst nations, but rather
nations (Lowe, & Staker, 2010). This regulatory upon the ethical obligation that each country
authority aligns with the jurisdictions established inherently possesses to apprehend perpetrators
by treaties, which prioritize the importance of regardless of their location. In the context of
collaboration through an accorded network. transnational crimes, cooperation relies heavily on
Collaboration is facilitated through a network mutual agreement, particularly with respect to the
agreement that permits the state to work technical aspects of transferring fugitives
alongside other nations in achieving effectiveness following an arrest. This is guided by the principle
in the elimination of transnational crimes, based of sunt servanda (Lowe, & Staker, 2010).
on shared interests (Lowe, & Staker, 2010). An additional type of jurisdiction is the
The fundamental tenet underlying exertion of jurisdiction beyond a country's
enforcement jurisdiction dictates that every state borders, which occurs in exceptional situations
is obligated to exercise its criminal jurisdiction when jurisdiction is exercised within the territory
over offenders within their jurisdictional reach, of another nation (Krisch, 2022; Schmidt, 2022).
regardless of their nationality or where the crime This idea of jurisdiction suggests that specific
is perpetrated. This extends to any geographic circumstances compel some nations to exert their
location where the offender is located or can be sovereignty in the territorial regions of other
found. Prior to its execution, an extradition nations without the approval of the country where
process must be initiated to apprehend the the individuals responsible is concealing
perpetrator. Under customary international law, all themselves. The use of extraterritorial jurisdiction
offenders must undergo trial or be surrendered to has sparked much debate in scientific
the jurisdiction of the nation in which the crime is communities due to the absence of direct contact
committed (au dedere aut punere), irrespective of and mutual consent between the nations where a
the presence of an extradition agreement criminal act occurred or where perpetrator resides
between the involved nations. However, (Michael, Goo, & Osaulenko, 2020). This implies
concerning transnational criminal activities like that the commencement and conclusion of the
money laundering across borders, while the process, commonly referred to as initiation and
universal jurisdiction approach of arresting the completion, are not directly or indirectly
connected. The principle of extra-territorial TABLE 1. TYPOLOGY OF TRANSNATIONAL
jurisdiction, demonstrated through the actions of AND INTERNATIONAL CRIMES IN APPLYING
the US Military Police, permits the arrest of US UNIVERSAL JURISDICTION APPROACH
military personnel stationed in the UK or South TOWARD CROSS-BORDER CRIME AND
Korea without the consent of those nations. INTERNATIONAL FUGITIVES
The utilization of extraterritorial jurisdiction Characteristics Transnational International
Crime Crime
is not limited to criminal law, as evidenced by the
Types of Crime Cross-border Genocide,
enforcement of the United States Anti-Monopoly Money War Crime,
Law under the Sherman Act of 1890 in the Laundering Piracy,
Terorism, etc
economic domain (Akhtar, 2019; Mahncke, 2006). General Term Hostis Crime Against
In the realm of the United States law, any Humanis Humanity
Generris
agreements, collusion, or conspiracies that strive Approach to Universal Universal
to impede trade in domestic and international combating Jurisdiction Jurisdiction
Principle & Principle
markets with the aim of monopolization are Enforcement
deemed unlawful according to this Act (Jones, Jurisdiction
Scale of crime Severe on Severe on
2003; Lande, & Zerbe, 2020). Apart from the Economy & Humanity
United States, it has been discovered that the Humanity
Locus delicti Operates Operates
European Court of Justice (ECJ) exercises Cross- Cross-
extraterritorial jurisdiction over the matters Jurisdiction Jurisdiction
Enforcement Formal Without
concerning business competition law (EU Request Basis Formal
Competition Law) (Zelger, 2020; Nishioka, 2020). (Voluntarily) Request
(Compulsory)
Employing Universal Jurisdiction in Combating Jurisdiction Trial in Trial in
Transnational Money Laundering National Court International
Court
It is necessary to employ universal (International
jurisdiction when enforcing laws across Criminal
Court/ ICC)
jurisdictions in order to track down and prosecute Similarity Against Against
those who commit transnational money Impunity Impunity
laundering crimes and to evade capture.
In accordance with the preceding account
Therefore, it is possible to dismantle the barrier of
in Table 1, it can be posited that international and
immunity. By comparing transnational crimes to
transnational crimes, encompassing money
international crimes and highlighting their
laundering, are the actions that run counter to
similarities and differences in Table 1, the
fundamental principles of human dignity and
principle of universal jurisdiction can be
judicial equity (Mugarura, 2011; Dreżewski,
employed.
Sepielak, & Filipkowski, 2012). the principle of absconded to foreign jurisdictions continues to
universal jurisdiction ought to be extended to the necessitate a formal appeal from the extraditing
perpetrators. There exist no legal gaps that such nation to the intervening nation. The
wrongdoers may utilize to evade their culpability aforementioned inquiry aligns with the concept of
as alternative jurisdictional principles can be universal jurisdiction, coupled with enforcement
employed to counteract any attempts to and treaty-based jurisdictions, emphasizing the
circumvent justice. importance of establishing a collaborative network
Therefore, a fundamental shared feature amongst nations through treaties. Therefore,
between the utilization of universal jurisdiction for universal jurisdiction is combined with
transnational and international crimes is the aim enforcement and treaty-based jurisdictions. The
of preventing perpetrators from avoiding core objectives are to establish a collaborative
accountability, which underlies the network among nations via treaties and to enable
implementation of this principle for both crime seamless implementation of universal jurisdiction
categories. The utilization of the universal and surrender of offenders without the need for
jurisdiction principle pertaining to transnational an arrest. Technical expertise would be used to
crimes aligns with the aut dedere aut punire support this effort. The reason for the
principle (Starke, 2008). The idea is conveyed aforementioned is that transnational crime
that individuals who commit transnational crimes, offenders usually face the trial in the jurisdiction of
including money laundering, are considered to be the country where the crime occurred. By
enemies of all mankind and, therefore, subject to adopting such a strategy, multiple nations can
universal jurisdiction. It means that they must collaborate to effectively and sufficiently address
either be tried in the state where the crime is transnational crimes through demonstrating
committed or where they are currently hiding. This shared concerns on transnational financial
pertains to the universal adversary of humanity. crimes.
All nations possess the power to detain offenders There are ongoing discussions regarding
regardless of their whereabouts, citizenship, and how universal jurisdiction can be enforced for
respective legal frameworks. money laundering offenses as they do not
The primary differentiating aspect in the typically fall under the category of delicta juris
utilization of universal jurisdiction in the context of gentium. This debate is reasonable given that
these two classes of offenses pertains to their money laundering has not been recognized as an
execution. The responsibility of enforcing the law international crime, unlike other offenses such as
against transnational offenders essentially lies war crimes, genocide, and ethnic demolition
with the respective national law of the country, (Wardani, Ali, & Barkhuizen, 2022; Samanta &
and the extradition of fugitives who have Hossain, 2022).
Thus, it is important to establish the profoundly violating societal norms of fairness and
definition and scope of universal jurisdiction as a equity. The fundamental concept behind the use
precursor to further discussion. Essentially, it is of universal jurisdiction for transnational offenders
an accord forged between nations acknowledging is exemplified by its application to transnational
the transnational and global nature of money financial crimes, particularly those involving
laundering as a crime against humanity. The 1997 money laundering. Every nation is under the
ASEAN Declaration on Transnational Crime responsibility for eliminating it without considering
acknowledged that money laundering is an act of the crime's whereabouts, the perpetrator or the
transnational crime. This perception is shared by victim's nationality. Instead, they should prioritize
the UN Convention on Organized Transnational the types of offense and the actions of the
Crime (2000) and the UN Convention on Anti- offenders, which cause significant harm to
Corruption (2003), which consider transnational societal structure and lay the groundwork for
crime as a worldwide issue. The crime of worldwide economic and financial instability
transnational money laundering may have a (Prayogo & Chornous, 2020).
hugely detrimental effect on both the global The concept of delicta juris gentium, which
financial system and the world economic order pertains to cross-border money laundering, is
due to the severity of damages and its negative evident in the array of the measures implemented
impacts. Its corrosive and harmful nature is well- by the FATF in different parts of the globe to
established. Money laundering has the potential prevent and eliminate this activity. The evidence
to harm the well-being of global populations. can be observed through the multiple measures
Conversely, those who engage in cross-border recommended by the FATF for the purpose of
money laundering conduct their activities confronting and eliminating international money
systematically and employ technology to carry out laundering offenses across the globe. It is
such actions in multiple jurisdictions. Currently, evidenced by the adoption and implementation of
transnational money laundering is considered a 49 FATF recommendations by 170 countries
form of transnational crime that has evolved into a worldwide, alongside the International Monetary
violation against international community. Fund (IMF) and World Bank, as referenced in
Therefore, it is reasonable to categorize this crime several United Nations conventions. The FATF
as being equivalent to delicta juris gentium mandates the criminalization of transnational
(Obokata, 2013). money laundering through its member countries'
Consequently, it is crucial to promptly national legislation and urges each member state
execute the principle of universal jurisdiction in to implement policies and measures to combat
addressing transnational crimes to prevent money laundering globally. The directive also
perpetrators from evading legal consequences for mandates that every member nation implement
local strategies and protocols to impede and highlights their corrosive and destructive nature.
eliminate money laundering at a global scale Thus, transnational money laundering is now
(Clark, 2004). The 1997 ASEAN Declaration on regarded as an international offense on par with
Transnational Crime emphasized that money delicta juris gentium.
laundering is a transnational offense. To combat The article examined the direct
this, the ASEAN member nations committed to repercussions of money laundering on the
creating national legislation and regulations financial security of states. Indonesia and Ukraine
pertaining to "Anti Money Laundering" with the have acknowledged that transnational crimes,
objective of criminalizing money laundering in including money laundering, have evolved into
foreign territories. the ASEAN member states worldwide predicaments necessitating global
have reached a consensus with regard to remedies. To address this, a worldwide approach
considering money laundering an international known as universal jurisdiction has been
dilemma that necessitates a global remedy. It is proposed. The institution of universal jurisdiction
worth noting that the same approach is deemed mandates that all nations are required to
applicable in the fight against corruption as a apprehend and try individuals responsible for
cross-border criminal activity (Syarifuddin, 2021). transnational money laundering offenses,
It is possible to perceive the use of universal regardless of their location, the perpetrators'
jurisdiction against transnational criminals, nationalities, or the legal structures of each
particularly those involved in cross-border money country. The detrimental effects of money
laundering as a global resolution which is one of laundering were examined based on the
the primary focuses of universal jurisdiction. As a components of financial security, including the
result, the use of universal jurisdiction against effectiveness of monetary and fiscal policies, the
transnational criminals, including those involved in security of currency and budget, and the
cross-border money laundering, can be viewed as economic well-being of banks and other
a global remedy. establishments. Ultimately, the implementation of
universal jurisdiction is anticipated to eradicate
C. CONCLUSION immunity, thereby ensuring that individuals who
Universal jurisdiction is founded on the commit heinous acts cannot evade justice,
recognition that transnational crimes, such as regardless of their whereabouts or attempts to
cross-border money laundering, pose a global conceal themselves.
threat and are considered crimes against
humanity. The significant harm and detrimental
impact inflicted upon the global financial system
and world economic order by these crimes
REFERENCES Arnone, Marco, & Borlini, Leonardo. (2010).
JOURNAL International anti‐money laundering
Ahmed, S. A. (2017). Practical application of anti- programs: Empirical assessment and
money laundering requirements in issues in criminal regulation. Journal of
Bangladesh: an insight into the disparity Money Laundering Control , Vol.13, Issue 3,
between anti-money laundering methods pp.226-271.
and their effectiveness based on resources https://doi.org/10.1108/1368520101105713
and infrastructure. Journal of Money 6
Laundering Control, Vol. 20, Issue4, Assalmani, M. N. B. Asyhar (2021). Corporate
pp.428-450. https://doi.org/10.1108/JMLC- Criminal Liability in Indonesian Law
09-2016-0042 Concerning Fund Transfer. Research
Akhavan, Payam. (2013). The rise, and Fall, and Horizon, Vol.1, (No.6), pp.229-236.
Rise, of International Criminal https://doi.org/10.54518/rh.1.6.2021.229-
Justice. Journal of International Criminal 236
Justice, Vol.11, (No.3), pp.527-536. Barkow, Rachel E. (2011). Federalism and
https://doi.org/10.1093/jicj/mqt 028. criminal law: what the feds can learn from
Akhtar, Zia. (2019). Mergers, extraterritorial the states. Michigan Law Review, Vol.109,
jurisdiction and convergence of EU and US Issue 4, pp.519-580.
law. European Review of Private https://dx.doi.org/10.2139/ssrn.1559251
Law, Vol.27, Issue1, pp. 59 – 81. Beebeejaun, Ambareen, & Dulloo, Lubnaa.
https://doi.org/10.54648/erpl2019004 (2023). A critical analysis of the anti-money
Amrani, Hanafi., & Ali, Mahrus. (2021). A new laundering legal and regulatory framework
criminal jurisdiction to combat cross-border of Mauritius: a comparative study with
money laundering. Journal of Money South Africa. Journal of Money Laundering
Laundering Control, Vol.25, Issue 3, Control, Vol.26,(No.2),pp.pp.401-417.
pp.540-550. https://doi.org/10.1108/JMLC- https://doi.org/10.1108/JMLC-12-2021-
06-2021-0059 0141
Arajärvi, Noora. (2011). Looking back from Burgess Jr, Douglas R. (2005). Hostis Humani
nowhere: is there a future for universal Generi: Piracy, Terrorism and a New
jurisdiction over international International Law. University of Miami
Crimes?. Tilburg Law Review, Vol.16, International and Comparative Law
Issue1,pp.5-29. Review, Vol.13, Issue 2, pp.293-341.
https://doi.org/10.1163/221125911X590949 https://repository.law.miami.edu/umiclr/vol1
3/iss2/2/
Chuasanga, Anirut., & Victoria, Ong Argo. (2019). Law Journal, Vol.63, Issue 2, pp.225-246.
Legal Principles Under Criminal Law in https://doi.org/10.3138/utlj.1117-3
Indonesia Dan Thailand. Jurnal Daulat Garrod, Matthew. (2019). The Emergence of
Hukum, Vol.2,(No.1),pp.131-138. “Universal Jurisdiction” in Response to
http://dx.doi.org/10.30659/jdh.v2i1.4218 Somali Piracy: An Empirically Informed
Clark, Roger S. (2004). The United Nations Critique of International Law’s
Convention Against Transnational “Paradigmatic” Universal Jurisdiction
Organized Crime. Wayne Law Crime. Chinese Journal of International
Review, Vol.50, (No.1), pp.161-184. Law, Vol.18, Issue 3, pp.551-643.
https://m.heinonline.org/HOL/LandingPage https://doi.org/10.1093/chinesejil/jmz025
?handle=hein.journals/waynlr50&div=15&id Hovell, Devika. (2018). The authority of universal
=&page= jurisdiction. European Journal of
Colangelo, Anthony J. (2013). What is International Law, Vol.29,(No.2),pp.427-
extraterritorial jurisdiction. Cornell Law 456. https://doi.org/10.1093/ejil/chy037.
Reiew, Vol.99, Issue 6, pp.1303-1352. Hülsse, R., & Kerwer, D. (2007). Global standards
https://scholarship.law.cornell.edu/clr/vol99/ in action: insights from anti-money
iss6/2/ laundering regulation. Organization, Vol.
Coombes, Karinne. (2011). Universal Jurisdiction: 14, Issue 5, pp.625-642.
A Means to End Impunity or a Threat to https://doi.org/10.1177/1350508407080311
Friendly International Relations. The Jones, Clifford A. (2003). Exporting Antitrust
George Washington International Law Courtroom to the World: Private
Review, Vol. 43, Issue 3, pp.419-466. Enforcement in a Global Market. Loyola
https://www.pro Consumer Law Review, Vol.16, Issue 4,
quest.com/docview/926417624/fulltextPDF/ pp.409-430.
DCE2223C0E974090PQ/1? https://lawecommons.luc.edu/cgi/viewconte
accountid=13771 nt.cgi?article=1251&context=lclr
Dreżewski, Rafał., Sepielak, Jan., & Filipkowski, Kemal, M. U. (2014). Anti-money laundering
Wojciech. (2012). System supporting regulations and its effectiveness. Journal of
money laundering detection. Digital Money Laundering Control, Vol.17, Issue4,
Investigation, Vol.9, Issue1, pp.8-21. pp.416-427. https://doi.org/10.1108/JMLC-
https://doi .org/10.1016/j.diin.2012.04.003 06-2013-0022
Farmer, Lindsay. (2013). Territorial jurisdiction Kontorovich, Eugene., & Art, Steven. (2010). An
and criminalization. University of Toronto empirical examination of universal
jurisdiction for piracy. American Journal of
International Law, Vol.104, Issue 3, pp.436- (No.4), pp.1361-1377.
453.https://doi.org/10.5305/amerjintelaw.10 https://doi.org/10.1108/JFC-09-2019-0117
4.3.0436 Maculan, Elena., & Gil, Alicia Gil. (2020). The
Krings, Britta Lisa. (2012). The Principles of Rationale and Purposes of Criminal Law
Complementarity and Universal Jurisdiction and Punishment in Transitional
in International Criminal Law: Antagonists Contexts. Oxford Journal of Legal
or Perfect Match. Goettingen Journal of Studies, Vol.40, Issue 1, pp.132-157.
International Law, Vol.4, Issue 3, pp.737- https://doi.org/10.1093/ojls/gqz033
763.https://web.archive.org/web/20180409 Mahncke, Hans. (2006). The emergence of
233736id_/http://www.gojil.eu/issues/ competition law regimes in the Asia-pacific
43/43_article_krings.pdf region: A contrarian perspective. Asia
Krisch, Nico. (2022). Jurisdiction unbound:(extra) Pacific Law Review, Vol.14, Issue 1, pp.1-
territorial regulation as global 18.
governance. European Journal of https://doi.org/10.1080/10192557.2006.117
International Law, Vol.33, Issue 2, pp.481- 88153
514. https://doi.org/10.1093/ejil/chac028 Masciandaro, D. (1999). Money laundering: the
Lande, Robert H., & Zerbe, Richard O. (2020). economics of regulation. European Journal
The Sherman act is a no-fault of Law and Economics, Vol. 7, pp.225-240.
monopolization statute: A textualist https://doi.org/10.1023/A:1008776629651
demonstration. American University Law Mekpor, Emmanuel Senanu, Aboagye, Anthony.,
Review., Vol. 70, Issue 2, pp.497- & Welbeck, Jonathan. (2018). The
588.https://www.proquest.com/ determinants of anti-money laundering
docview/2492324963/fulltextPDF/61B35F9 compliance among the Financial Action
2F5364F2BPQ/1?accountid=13771 Task Force (FATF) member states. Journal
Langer, Máximo. (2011). The diplomacy of of Financial Regulation and
universal jurisdiction: The political branches Compliance, Vol.26, (No.3), pp.442-459.
and the transnational prosecution of https://doi.org/10.1108/JFRC-11-2017-
international crimes. American Journal of 0103.
International Law, Vol.105, (No.1), pp.1-49. Menon, Sundaresh., & Siew, Teo Guan. (2012).
https://doi.org/10.5305/amerjintelaw.105.1. Key challenges in tackling economic and
0001. cyber crimes: Creating a multilateral
Le Nguyen, Chat. (2020). National criminal platform for international co‐
jurisdiction over transnational financial operation. Journal of Money Laundering
crimes. Journal of Financial Crime, Vol. 27 Control, Vol. 15, No. 3, pp.243-256.
https://doi.org/10.1108/1368520121123801 border cartel cases: a Japanese approach
6 to ‘extraterritorial application. Journal of
Michael, Bryane., Goo, Say-Hak., & Osaulenko, Antitrust Enforcement, Vol.8, Issue 3,
Svitlana. (2020). The extra-territorial pp.590-605.
application of corporate governance https://doi.org/10.1093/jaenfo/jnz033
standards in China. Transnational Legal Nurdin, Boy., & Turdiev, Khayitjon. (2021).
Theory, Vol.11, Issue 4, pp.436-453. Paradigm of Justice in Law Enforcement in
https://doi.org/10.1080/20414005.2020.174 the Philosophical Dimensions of Legal
4890 Positivism and Legal Realism. Lex
Moffett, Luke. (2015). Elaborating justice for Publica, Vol.8, (No.2), pp.65-74.
victims at the international criminal court: https://doi.org/10.58829/lp.8.2.2021.65-74
Beyond rhetoric and the hague. Journal of Obokata, Tom. (2013). Maritime piracy as a
International Criminal Justice, Vol.13, Issue violation of human rights: a way forward for
2, pp.281-311. its effective prevention and
https://doi.org/10.1093/jicj/mqv 001 suppression?. The International Journal of
Mugarura, Norman. (2011). The global anti‐ Human Rights, Vol.17, Issue1, pp.18-34.
money laundering court as a judicial and https://doi.
institutional imperative. Journal of Money org/10.1080/13642987.2012.690218
Laundering Control, Vol. 14, No. 1, pp. 60- Ofoeda, I., Agbloyor, E. K., Abor, J. Y., & Osei, K.
78.https://doi.org/10.1108/1368520111109 A. (2022). Anti‐money laundering
8888 regulations and financial sector
Nance, Mark T. (2018). The regime that FATF development. International Journal of
built: an introduction to the Financial Action Finance & Economics, Vol.27, Issue 4,
Task Force. Crime, Law and Social pp.4085-4104.
Change, Vol.69, Issue 2, pp.109-129. https://doi.org/10.1002/ijfe.2360
https://doi.org/10.1007/s10611-017-9747-6. Panáková, Jana. (2011). Law and politics of
Nazar, Sadia., Raheman, Abdul., & ul Haq, universal jurisdiction. Amsterdam Law
Muhammad Anwar. (2023). The magnitude Forum, Vol.3, Issue 3, pp.49–72.
and consequences of money http://doi.org/10.37974/ALF.192
laundering. Journal of Money Laundering Pavlidis, Georgios. (2021). Financial action task
Control.Article in Press. https://doi.org/10. force and the fight against money
1108/JMLC-09-2022-0139 laundering and the financing of terrorism:
Nishioka, Kazuaki. (2020). International scope of Quo vadimus?. Journal of Financial
the Japanese Anti-monopoly Act in cross-
Crime, Vol.28, (No.3), pp.765-773. Reeves, Anthony R. (2017). Liability to
https://doi.org/10.1108/JFC-09-2019-0124. international prosecution: The nature of
Popa, George Dorel. (2012). International universal jurisdiction. European Journal of
cooperation in the struggle against trans- International Law, Vol.28, Issue 4, pp.1047-
border organized crime and money 1067. https://doi.org/10.1093/ejil/chx064
laundering. Contemporary Readings in Law Samanta, Chowdhury Nujhat., & Hossain,
and Social Justice, Vol. 4 Issue 2, pp.575- Belayet. (2022). Implementation of
578.https://go.gale.com/ps/i.do? Diplomatic Assurance Against Torture: The
p=AONE&u=googlescholar&id=GALE| Way to Reduce the Refugee Crisis in South
A321579696&v=2.1&it=r&sid=AONE&asid Asia. Lex Publica, Vol.9,(No.1),pp.1-29.
=7af7d94a https://doi.org/10.58829/lp.9.1.2022.1-29.
Popko, V. (2019). Social requirements and the Sarigul, Hasmet. (2013). Money laundering and
role of globalization in the formation of the abuse of the financial system. International
transnational criminal law. Journal of Business and Management
Entrepreneurship, Economy and Law, Studies, Vol.2, Issue 1, pp.287-301.
No.8, pp.236-243 [In Ukrainian]. http://pgp- https://www.researchgate.net/publication/2
journal.kiev.ua/archive/2019/8/45.pdf. 56040462_Money_Laundering_and_Abuse
Popko, V. (2021). Convergence of criminal and _of_the_Financial_System
legal systems in the globalization of crime. Sasmito, Joko. (2017). Application of the
Entrepreneurship, Economy and Law, Retroactive Principle in Criminal Law on
No.1, pp.227-237 [In Ukrainian]. http://pgp- Gross Human Rights Violations. Lex
journal.kiev.ua/archive/2021/1/40.pdf. Publica, Vol.4,(No.2),pp.775-781.
Popović, I. (2021). The extra-territorial jurisdiction https://doi.org/10.58829/lp.4.2.2017.775-
in the case-law of the European court of 781.
human rights and contemporary Scharf, Michael P. (2012). Universal jurisdiction
challenges. Politeia, Vol. 11, Issue 22, and the crime of aggression. Harvard
pp.147-164. Internationall Law Journal, Vol.53, Issue 2,
https://doi.org/10.5937/politeia0-33972 pp.357-389.https://harvardilj.org/wp-
Prayogo, Galang., & Chornous. Yulia. (2020). content/uploads/sites/15/2012/10/
Conceptualization of Future Cryptocurrency HLI201.pdf
Laws in Indonesia and Ukraine. Lex Schmidt, Julia. (2022). The legality of unilateral
Publica, Vol.7, (No.2),pp.56-68. extra-territorial sanctions under
https://doi.org/10.58829/lp.7.2.2020.56-68. international law. Journal of Conflict and
Security Law, Vol.27, Issue1, pp.53-81. Teichmann, Fabian. (2020). Recent trends in
https://doi.org/10.1093/jcsl/krac005 money laundering. Crime, Law and Social
Sekati, P. (2022). Assessing the Effectiveness of Change, Vol.73, Issue 2, pp.237-247.
Extradition and the Enforcement of Extra- https://doi.org/10.1007/s10611-019-09859-
territorial Jurisdiction in Addressing Trans- 0
national Cybercrimes. Comparative and Van Der Wilt, Harmen. (2011). Universal
International Law Journal of Southern jurisdiction under attack: An assessment of
Africa, Vol. 55, Issue 1, pp.1-36. African misgivings towards international
Shehu, A. Y. (2012). Promoting financial inclusion criminal justice as administered by western
for effective anti-money laundering and states. Journal of International Criminal
counter financing of terrorism Justice, Vol.9, Issue 5, pp.1043-1066.
(AML/CFT). Crime, law and social https://doi.org/10.1093/jicj/mqr045
change, Vol. 57, Issue 3, pp.305-323. Wangga, Maria Silvya Elisabeth., Wirawan,
https://doi.org/10.1007/s10611-011-9351-0 Aditya., & Kardono, R. Bondan Agung.
Simmons, Beth A., Lloyd, Paulette., & Stewart, (2022). Corruption and Money Laundering
Brandon M. (2018). The global diffusion of Perspective of Criminal Law and
law: Transnational crime and the case of Criminology. Research Horizon Vol.2,
human trafficking. International (No.2), pp.363-373.
Organization, Vol.72, Issue2, pp.249-281. https://doi.org/10.54518/rh.2.2.2022.363-
https://doi.org/10.1017/S002081831800003 373
6 Wardani, Alya., Ali, Mahrus., & Barkhuizen, Jaco.
Sultan, Nasir., & Mohamed, Norazida. (2022). (2022). Money Laundering through
The role of information sharing in Cryptocurrency and Its Arrangements in
combating money laundering: the Money Laundering Act. Lex Publica, Vol. 9,
importance and challenges of mutual legal (No.2),pp.49-66.
assistance for developing jurisdictions like https://doi.org/10.58829/lp.9.2.2022.49-66.
Pakistan. Journal of Money Laundering Yasaka, N. (2017). Knowledge management in
Control, (ahead-of-print). international cooperation for anti-money
https://doi.org/10.1108/JMLC-09-2022- laundering. Journal of Money Laundering
0128. Control, Vol. 20, Issue 1, pp.27-34.
Syarifuddin, Muhammad. (2021). Legal Heuristic https://doi.org/10.1108/JMLC-09-2015-
Approach in Judicial Practice. Lex 0040
Publica, Vol.8, (No.2), pp.1-13. Zafarullah, H., & Haque, H. (2023). Policies,
https://doi.org/ 10.58829/lp.8.2.2021.1-13. instrumentalities, compliance and control:
combatting money laundering in the concept of crime. New York: Springer
Bangladesh. Journal of Money Laundering Science & Business Media.
Control, Vol. 26, Issue 1, pp.189-204. Lowe, Vaughan. & Staker, Christopher. (2010).
https://doi.org/10.1108/JMLC-10-2021- Jurisdiction. In Evans, Malcolm D. (2010).
0109 International Law, 3rd ed. Oxford: Oxford
Zavoli, I., & King, C. (2021). The Challenges of University Press.
Implementing Anti‐Money Laundering Starke, J. G. (2008). Pengantar Hukum
Regulation: An Empirical Analysis. The Internasional 2. Trans. Djajaatmadja, B. I.
Modern Law Review, Vol. 84, Issue 4, 10th ed. Jakarta: Sinar Grafika.
pp.740-771. https://doi.org/10.1111/1468- Stessens, G. (2000). Money laundering: a new
2230.12628 international law enforcement model  (Vol.
Zelger, Bernadette. (2020). EU Competition law 15). Cambridge: Cambridge University
and extraterritorial jurisdiction–a critical Press.
analysis of the ECJ's judgement in
Intel. European Competition
Journal, Vol.16, (No.2-3), pp.613-627. PROCEEDING
https://doi.org/10.1080/17441056.2020.184 Atmasasmita, Romli. (2004). Cross-Border &
0844 Transnational Crimes. In Prosiding
Kepailitan dan Transfer Asset Secara
Melawan Hukum. Bogor: Bareskrim Polri &
BOOK Pusat Pengkajian Hukum.
Bassiouni, M. Cherif. (1974). International
extradition and world public order. Leiden: ONLINE SOURCE
Sijthoff. Amnesty International. (2013). How General
Bassiouni, M. Cherif. (1997). International Pinochet’s Detention Changed the Meaning
Criminal Law Conventions and their Penal of Justice. Retrieved from
Provisions. Leiden: Brill. https://www.amnesty.org/en/latest/news/20
Bingham, Tom. (2011). The Rule of Law. London: 13/10/how-general-pinochets-detention-
Penguin Group. changed-meaning-justice/.
Boister, Neil. (2018).  An introduction to Budiantoro, S. (2016). menyebutkan bahwa
transnational criminal law. Oxford: Oxford kerugian akibat uang haram berdasarkan
University Press. data tahun 2016 mencapai 2.500 trilliun
Hoefnagels, Gerardus Petrus. (ed.). (2013). The Rupiah.Retrieved from https://www.indo
other side of criminology: An inversion of premier.com/ipotgo/newsDetail.php?
Dana_Gelap_Tembus_Rp2_500_Triliun_Fi
skal_Moneter_Indonesia_Rentan&news_id
=60544&group_newsIPOTNEWS.
EUROPOL High Tech Crime Centre. (2007). High
Tech Crimes Within the EU: Old Crimes
New Tools, New Crimes New Tools (Public
Version). Threat Assesment. EUROPOL
High Tech Crime Centre, Agustus 2007.
Retrieved from https://www.enisa.europa.
eu/topics/csirts-in-europe/files/event-files/E
NISA_Europol_threat_assessment_2007_
Dileone.pdf.
Human Rights Watch. (2003). Belgium: Universal
Jurisdiction Law Repealed. Retrieved from
https://www.hrw.org/news/2003/08/02/belgi
um-universal-jurisdiction-law-repealed.

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