Volume 5 Issue 2, December 2020: pp. 194-205. Copyright ©2020 TALREV. Faculty of Law Tadulako University, , Central , . TALREV ISSN: 2527-2977 | e-ISSN: 2527-2985. Open acces at: http://jurnal.untad.ac.id/index.php/TLR

LAW ENFORCEMENT IN ILLEGAL LEVIES BY PUBLIC OFFICIALS ASSOCIATED WITH THE THEORY OF COST AND BENEFIT ANALYSIS

Miranti Putri Pratiwi

Padjadjaran University JL. Raya Bandung, Sumedang KM. 21, Jatinagor, Bandung, West , 45363, Indonesia Telp./Fax: +62-22-84288827 E-mail: [email protected]

Submitted: Jul 23, 2020; Reviewed: Aug 30, 2020; Accepted: Dec 23, 2020

Abstract Public officials who carry out illegal levies are threatened with article 12e of Act 31 of 1999 as amended with Act 20 of 2001 concerning Amendments to Act 31 of 1999 con- cerning Eradication of Corruption. In practice, illegal levies are often carried out in relatively small amounts and are massive. Law enforcement of illegal levies performed by public officials is carried out with the establishment of the Saber Pungli Task Force based on Presidential Regulation (Perpres) 87 of 2016 concerning the Clean-Sweep Illegal Levies Task Force and it will be associated with the theory of Cost and Benefit Analysis. This research uses the normative legal research method by specializing in the approach by using national legal rules to find out law enforcement in cases of illegal levies performed by public officials. The results of this study indicate that law enforce- ment against illegal levies performed by public officials through the establishment of the Saber Pungli Task Force Team is in line and related to the application of the theory of Cost and Benefit Analysis that compares costs incurred by law enforcement with the benefits obtained through the calculation of losses carried out by illegal levies.

Keywords: Illegal Levies; Law Enforcement; Public Officials

INTRODUCTION tism (KKN), in reality, this is common in One obstacle in the implementation Indonesia.1 of public service activities is illegal levies. The practice of illegal levies in the Simply put, illegal levies can be interpret- bureaucracy is caused by the lack of con- ed as the imposition of fees in the place trol and supervision among government that should not be charged. Most illegal agencies. Although several internal and levies are collected by officials or appa- external supervision institutions have been ratus, although it is illegal and is classified established, the habit of illegal levies as part of corruption, collusion, and nepo- among bureaucrats has not diminished or

1Mahmud Mulyadi, “Pungli: Antara Suap Atau Pemer- asan”, Paper in the Panel Discussion with the Topic: Perbedaan Suap dan Pemerasan? Dan Akibatnya Ter- hadap Kemudahan Berusaha di Indonesia”, Surabaya, 04 March 2019, p.. 1.

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been eliminated. In general, illegal levies non-public officials are applied as a form are performed by public officials in the of illegal levies offense regulated in article lower class category. The motive is to in- 368 paragraph (1) of the Criminal Code as crease their income due to the low average quoted: of official salaries. The high-level bureau- (1) Anyone with the intent to unlawful- ly benefit himself or others, force a cracy does corruption to increase their in- person with violence or threat of come, then the low-level bureaucracy does violence to give something away, wholly or partly owned by that it through illegal levies. Opportunities, person or another person, or to lack of supervision, and low bureaucratic make debt or write off a debt, threatened with illegal levies with ethics are driving factors of illegal levies.2 a maximum jail sentence of nine President Joko Widodo issued the months.

Presidential Regulation (Perpres) 87 of Unlike the extortion article which 2016 concerning the Clean-Sweep Illegal is often applied to the practice of non- Levies Task Force (hereinafter mentioned public officials, illegal levies define as a as Saber Pungli Task Force) which was levy that is carried out illegally and is not passed on 21 October 2016.3 This regula- based on rules. Public officials who do tion is a form of impact anticipation this then lead to the practice of extortion caused by illegal levies. Illegal levies be- crimes regulated in article 12 e Act 31 of come one of the actions that are already 1999 as amended by Act 20 of 2001 con- familiar to the public. Eradication of ille- cerning Amendments to Act 31 of 1999 gal levies does not lie in the amount of concerning Eradication of Corruption loss caused, but rather the habitual roots (hereinafter mentioned as the Anti- that want to be eliminated.4 Corruption Act). The elements in Article The characteristics of illegal levies 12e of the Anti-Corruption Act differ from carried out by civil society and public of- the elements in Article 368 Paragraph (1) ficials must be distinguished, this will of the Criminal Code in which the threat have an impact on the provisions that will of violence is not listed as an element that be applied between the two. Provisions on must be proven, while the element of illegal levies carried out by civil society or force should be proven. As for article 12e, the Anti-Corruption Act reads: 2 Halim, (2004), Pemberantasan Korupsi, Jakarta: Raja- wali Press, p.. 46. (e) public servants or state adminis- 3https://saberpungli.id/tentang, accessed in 03 March trators who intend to benefit them- 2019 at 18.30 WIB. 4Ibid. selves or others unlawfully, or by

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abusing their power to force some- the West Java Province level to date are one to give something, pay, or re- 10.744 cases. ceive payment in pieces, or to do something for themselves; The handling of illegal levies cases

is carried out starting with the preliminary The legal subject in Article 12e of case exposure where the Saber Pungli the Anti-Corruption Act, namely ‘Civil Task Force will submit the case to their Servants or State Administrators’ is a per- respective departments whether the case son who is given certain authority based will go to the general crime, special crime on the Statutory Regulations so that he/she (corruption), or returned to the public of- has a position and certain powers, so that ficial agency to give disciplinary punish- it is narrowed in scope and slightly differ- ment in the form of administrative sanc- ent from the legal subject in the Criminal tions to the perpetrator. Concerning OTT Code which stating ‘whoever’. for public officials, the Saber Pungli Task According to the Head of the Saber Force of the West Java Provincial Gov- Pungli Task Force Komjen Pol. Dwi Pri- ernment has conducted OTT on four pub- yatno, the case of the Illegal Arrest Opera- lic officials, including the Head of the tions (hereinafter abbreviated OTT) case Bandung City Licensing Office, the Head carried out by the Saber Pungli Task of the Village District, an individual in the Force since a year after it was formed in National Land Agency (BPN), and an in- 2016. It has conducted as many as 1.316 dividual of BKD Health Office of Garut OTTs on a variety of illegal levies cases Regional Hospital. The case handling of throughout Indonesia. Illegal levies cases the three public officials (the Head of the that often occur in the fields of education, Bandung City Licensing Office, the Na- law enforcement, licensing, and staffing.5 tional Land Agency (BPN) officer, and In the subsequent developments in 2019, the individual in BKD Health Office of based on the results of an interview with Garut Regional Hospital) was handed over one of the staff members of the West Java to the investigators, categorized into cor- Provincial Government Saber Pungli Task ruption, and submitted to trial in the Spe- Force Dwi Ismarianto stated that the total cial Court for Corruption. Whereas the number cases carried out by the OTT at Head of the Village District is subject to

administrative sanctions in the form of 5http://kabar24.bisnis.com/read/20171112/16/708273/ott disciplinary punishment regulated in Gov- -saber-pungli-dalam-setahun-1.316-kasus-ditangani accessed on 30 January 2018 at 18.30 WIB.

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ernment Regulation 53 of 2010 concern- the existence of the regulation or policy ing Discipline of Civil Servants, which results in greater benefits compared to the caused the dismissal from the Head Vil- costs incurred in the process of forming lage District position. these regulations and policies.6 Based on the aforementioned data, The cases of illegal levies performed this research is interested to find out by public officials in a relatively small whether the law enforcement process car- amount which are then processed by law ried out by the Saber Pungli Task Force as enforcement by criminal procedure and an effort to eradicate illegal levies, espe- subject to articles regulated in the Crimi- cially those carried out by public officials nal Code and the Anti-Corruption Act and are following the law, can achieve the ul- must be examined in the District Court timate goal of punishment itself? Fur- and Higher District Court of Corruption, it thermore, the amount of illegal levies is still needs to be investigated whether it is relatively small, is the budgetary cost of in line with the implementation of cost the law enforcement process balanced and benefit analysis. with the benefits obtained when taking Accordingly, it is interesting to con- action against illegal levies actors associ- duct research on law enforcement against ated with the theory of Cost and Benefit illegal levies performed by public officials Analysis (CBA)? associated with the theory of CBA with Cost and Benefit Analysis (hereinaf- the title “Law Enforcement in Illegal Lev- ter mentioned as CBA) is a systematic ap- ies Case by Public Officials Associated proach to consider weaknesses (costs) and With the Theory of Cost and Benefit strengths (benefits) for existing choices. Analysis”. The CBA method is used to assess the feasibility of a proposed policy. It con- ANALYSIS AND DISCUSSION verts policy impacts into monetary calcu- Jimly Asshiddiqie stated that law lations based on the premise that each pol- enforcement is the process of efforts for icy must have an economic impact. CBA the establishment or functioning of legal on regulation or policy is an analysis of norms as a real guideline for behavior in the costs and benefits that will result from legal relations of public and state life. Law the formation or making of a regulation or 6Guidelines for Legal Drafting in Legislation, the Draft- policy so that it can be estimated whether ing Center for the Expertise of the House of Representa- tives of the Republic of Indonesia.Accessed from www.dpr.go.idon 28 February 2020 at 14.00 WIB.

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enforcement is a process to make legal illegal levies through the establishment of wishes come true. The so-called legal Saber Pungli Task Force. This instruction wishes here are none other than the on the supervision of illegal levies was thoughts of the legislature which are for- also set forth by the Instruction of the mulated in the legal regulations and legis- Minister of Internal Affairs Number lation. The formulation of the lawmakers’ 180/3935/SJ concerning the Supervision thoughts as outlined in the legal regula- of Illegal Levies in the Implementation of tions and legislation will also determine Local Government. how law enforcement is carried out.7 Ac- In carrying out its duties, principal, cording to Barda Nawawi Arief, law en- and functions, the Saber Pungli Task forcement is nothing but an effort to real- Force maintains four functions, i.e. Intel- ize or apply legal provisions to real ligence, Prevention, Enforcement, and Ju- events. When dealing with criminal law, dicial. The Intelligence task force is enforcement means efforts to realize or tasked with mapping out agencies that are apply criminal law into concrete actions. prone to illegal levies. In this section, the Paragraph (2) Article 286 Act 23 of task force can collect data and information 2014 concerning Local Government stipu- from various parties related to illegal lev- lates that “Local governments are prohib- ies. The next task force is Prevention, in ited from making levies or other designa- which case the task force can make pre- tions outside those stipulated in the Act”. ventive and educative efforts. The third This article is an effort to prevent the oc- task force is the function in the Enforce- currence of illegal levies practices. It has ment area, its authority is more on repres- damaged the order of the community, na- sive efforts. This task force can receive tion, and state life so that efforts to eradi- reports from the public through existing cate it are firm, integrated, effective, effi- information technology, social media, or cient, and able to cause a deterrent effect. direct complaints. Also, this task force can Then as a follow-up of concerns about the coordinate to plan and conduct OTT. The practice of illegal levies, the Government last task force is Judicial which is a deci- through Presidential Regulation (Perpres) sive part of the whole task force. The de- 87 of 2016 specializes in the prevention of cisive part in this case is to provide rec-

ommendations related to sanctions that 7 Satjipto Raharjo, (2009), Penegakan Hukum Sebagai will be given to illegal levies offenders. Tinjauan Sosiologis, Yogyakarta: Genta Publishing, p.. 25.

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The Judicial task force can assist the task ternal or verbal reprimand sanctions, post- of the judiciary body in efforts to eradi- ponement of training, postponement of cate illegal levies. One resort that can be salaries, removed from office, transfers, done is to make arrests, hearings, and de- demotion, and firing. tention. Duties and functions of the work- In cases which are then included in ing group of the judicial task force i.e. an- the administrative domain, if conducted alyzing, evaluating, and case exposition by the state civil apparatus or public offi- will determine whether the case will be cials, the Saber Pungli Task Force will categorized as a general crime (Pidum), first look at the value of confiscated evi- special crime (Pidsus) as corruption case, dence. The Task Force will assess whether or in the administrative domain.8 the handling of a case will charge the state First, concerning cases categorized with a greater cost than the evidence al- as the general criminal domain (Pidum), legedly obtained by the perpetrator. This the case is delegated to the Law Enforce- will pertain to the return of state money to ment Working Group (Gakum) to conduct the state treasury and will be concluded the case handling process as the mecha- based on the results of the case discussion nism in the general crime investigation conducted by the Law Enforcement process. Second, if the case is categorized Working Group (Gakum). in the special crime (Pidsus) domain, the Article 8 of Presidential Regulation case will be transferred to the Law En- 87 of 2016 states that minis- forcement Working Group (Gakum) and tries/institutions and local governments followed up as is the mechanism in the carry out the eradication of illegal levies special crime (Pidsus) domain. Last, in the in their respective work environments, in administrative domain, the case will be doing so, ministries/institutions and local delegated to the inspectorate division governments form a unit to eradicate ille- where the unscrupulous institution is sus- gal levies. This unit is part of the internal pected of practicing illegal levies is shel- supervisory unit or other work units in tered. In this case, the punishment will be their respective work environments. Fur- provided in the form of administrative thermore, the agency will notify the han- sanctions. For example, in the form of in- dling report to the Saber Pungli Task

Force as stated in the regulation that the 8Interview wtihDr. (Cand) Uyun Saepul Uyun, S.H., M.H., The Head eradication of illegal levies units in each of Corruption Sub-Unit, Sat Reskrim Polrestabes Bandung, 06 March 2019 in Polrestabes Kota Bandung.

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ministry/institution and local government Illegal levies are regulated in the in carrying out their duties has to coordi- Criminal Code (KUHP) and constitute nate with the Saber Pungli Task Force. illegal levies offenses regulated in the An- The Saber Pungli Task Force has its ti-Corruption Act so that it is included as a authority to determine whether the illegal criminal offense that carries the threat of levies committed by individuals or per- criminal sanctions. However, after the es- sons constitute the domain of general tablishment of the Saber Pungli Task crime, special crime, or limited to the ad- Force, illegal levies can be subject to ad- ministrative domain as explained above. ministrative sanctions. It is said that poli- The law enforcement carried out by the cy or action that is not entirely based on Saber Pungli Task Force is the initial law is something that can be justified as stage before an investigation is carried out long as the policy or action is not contrary by the Police. This initial stage is the be- to the law. So, the essence of law imple- ginning of illegal levies settlement wheth- mentation does not only include law en- er it will be categorized in general crime, forcement, but also maintenance of peace, special crime (corruption), or administra- because it is a process of harmonizing the tive domain. values of the method and real behavioral The law enforcement process, which patterns aimed at achieving peace in the only been applied within the domain of society. the criminal justice sub-system, later be- In the process of law enforcement, it comes the entry point in the handling and is expected to have an optimal result, so settlement of illegal levies while it is not that criminal law functions effectively to always included in the domain of the court preventing prohibited acts and if those after the formation of the Saber Pungli rules are violated, law enforcement offi- Task Force. Based on the description cials can carry out their functions effec- above, that the settlement of illegal levies tively. The efforts to realize optimal crim- can be done with administrative processes inal law enforcement cover a variety of and sanctions on the relevant institution or ways and approaches. Every method and agency with the establishment of the Task approach used will have implications for Force for illegal levies in each relevant the results to be achieved. One approach institution or agency. that can be used to realize optimal crimi-

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nal law enforcement is an economic (ana- be incurred by the government to tackle lytical) approach.9 the crime through law enforcement offic- The economic analysis relates to the ers are greater than the number of profits principle of efficiency if it is linked to im- derived by the perpetrators from commit- posing sanctions for perpetrators of ting criminal acts, then the optimization of crimes, the first thing to consider is what law enforcement will not be realized. forms of sanctions are available that will Therefore, what needs to be done is to use be imposed on the perpetrator. Then, from other instruments in preventing the crime the existing forms of sanctions, it ana- from happening. In other words, the ac- lyzed which are the most efficient in terms tions to be banned and the costs of law of the principle of costs and benefits as it enforcement when violations occur are is very important with efforts to tackle greater than the benefits to be obtained, it crime. The problem of dealing with crime should not be prohibited and dealt with by is closely related to the budget allocation criminal law instruments.11 available, while the analysis of costs and One of the purposes of the Saber benefits is also related to how much re- Pungli Task Force is to establish an early sources must be allocated to counter the warning system where it prioritizes pre- crime. vention rather than enforcement. In com- CBA of a regulation or policy is an piling the budget, the work mechanism analysis of the costs and benefits that will pattern of Task Force itself emphasizes result from the formation or making of a the soft treatment side in the form of so- regulation or policy so that it can be esti- cial sanctions. Thus, more budget is given mated whether the existence of the regula- at the prevention stage than at the en- tion or policy results in greater benefits forcement stage.12 compared to the costs incurred in the pro- Referring to the principle of ration- cess of establishing the regulations or pol- ality in the economic analysis of the law 10 icy. If the losses due to criminal acts (af- ter being cashed) and the costs that must 11 David D. Friedman, “Should the Characteristics of Victims and Criminals Count? Payne v Tennessee and Two Views of Efficient Punishment”, Article in Boston 9Mahrus Ali, (2008), Penegakan Hukum Pidana Yang College Law Review, Vol. 34, 1993, p. 732-733. To Optimal (Perspektif Analisis Ekonomi Atas Hukum), learn more about the criminal sanction, especially in the Jurnal Hukum Nomor 2 Vol. 15, Yogyakarta: UII, p.. criminal law analysis, read Robert Cooter, “Prices and 223-238. Sanctios”, Article in Columbia Law Review, Vol. 84, 10Guidelines for Legal Drafting in Legislation, the Draft- 1984, p. 1524-1531. ing Center for the Expertise of the House of Representa- 12Interview with Iwan Arto Koesomo, S.H., M.H., member of Saber tives of the Republic of Indonesia.Accessed from Pungli Task Force Kejaksaan Negeri Kota Bandung on 4 March 2020 in Kejaksaan www.dpr.go.id on 14 April 2020 at 20.00 WIB. Negeri Kota Bandung.

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which describes that rational actors al- said that the charged budget for the Prose- ways calculate the costs and benefits to be cutor’s Office in the prosecution of special obtained when committing a criminal act criminal cases including criminal acts of of corruption. If the benefit or profit is corruption is Rp. 100.000.000.00 for just greater than the cost or loss, they will one case. Unlike the general crime case, commit a criminal act of corruption and the Prosecutor's Office has a budget of Rp. vice versa. Because humans are rational 3.500.000.00 for every single case in the beings, as a preventive measure is when prosecution stage. In arresting the suspect, someone commits a criminal act of cor- the Saber Pungli Task Force at the Attor- ruption, then the criminal sanctions im- ney General’s level has a maximum budg- posed must exceed the seriousness of the et of Rp. 3.000.000.00 for one activity. criminal act of corruption, in other words, Overall, the actions were taken by the the losses/costs to be borne by the perpe- Task Force in the enforcement stage, the trator must be greater than the benefits Law Enforcement Working Group by the obtained by committing a crime.13 Task Force possess a maximum budget of One of the factors that influenced Rp. 90.000.000.00 for one year for all the Saber Pungli Task Force Team in de- cases. This budget includes the act of ar- termining the imposition of actions or rest, the whole process up to submission sanctions against reported illegal levies is to the agency of origin for administrative the fees. The amount of fees in carrying sanctions. out illegal levies is very relative, no matter In addition to the prevention efforts how small it is, illegal levies are legal acts in enforcing illegal levies carried out by and must have legal consequences. How- public officials, another thing that needs ever, taking action against reported illegal to be improved is increasing the possibil- levies must not be detrimental to the state ity of criminal offenders to be arrested, even though enforcement of illegal pay- processed, and then punish. Because in ments has its budget. doing so the ultimate goal of justice can One example of the use and absorp- be realized. When the possibility of a law tion of the budget based on research re- enforcement process is high, law en- sults at the Prosecutor’s Office as one of forcement will be optimal, because there the Criminal Justice Sub-Systems, it is will be fewer people commit the same

crime, and as such, not many costs must 13 Ibid.

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be spent to exterminate the crime and fi- officials will bear all the costs of their ac- nance the operationalization of law en- tions. forcement. According to Becker15, a person’s According to Iwan Arto14, the pur- decision to commit a crime is based on pose of enforcement and control of illegal calculating the benefit-cost analysis of the levies carried out by civil society and pub- crime itself. If the expected benefit of lic officials is a deterrent effect. By im- crime exceeds its expected cost, then as a plementing the application of social sanc- rational economic actor, individuals will tions in addition to administrative sanc- tend to commit crimes. Conversely, if the tions that have been given at the time it calculation of an individual shows that the was revealed, the Saber Pungli Task expected cost exceeds the expected bene- Force will publish related cases of the re- fits of a crime, then the person concerned ported illegal levies. Later, it will be will not commit the action. caused in the more orderly manner of re- The wanted doctrine to be devel- lated public services, where other public oped is that law enforcement is solely for officials are less likely to do so due to in- formal law enforcement. Every law en- tensified social sanctions. forcement should not put aside the materi- The implementation of administra- al law aspect. This is the hope, but it never tive sanctions is directly related to the po- manifested. The realization of this aspect sition of a public official in an institu- can be seen from another perspective, tion/agency that will affect the responsi- namely the consideration of cost and ben- bilities of the position carried by the pub- efit analysis. The model of law enforce- lic official. Thus, when a public official ment that does not consider cost and bene- whose main purpose is to obtain profits fit are wasteful in using state funds to outside of the earning by commits illegal handle a case whose rate of occurrence in levies, accordingly they must receive ad- the field is very massive with relatively verse administrative sanctions. Later on, small nominal costs. Hence, analysis from public officials tend not to carry out these actions with the possibility that they will get a higher degree of sanctions and ex- 15Becker, G.S., Crime and Punishment: An Economic Approach, Journal of Political Economy, 1968, p.. 1-13. ceed the gained profit. Therefore, public Accessed from https://feb.ugm.ac.id/en/research/lecturer-s- article/artikel-dosen/826-penegakan-hukum-dan- pencegahan-tindak-kejahatan-dalam-tinjauan-ilmu- 14 Ibid. ekonomi.

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this point of view looks at the efficiency remidium can be the last alternative in side. handling an action by considering the costs and benefits obtained in handling a CONCLUSION case for the creation of optimal and effi- The process of law enforcement cient law enforcement. against illegal levies carried out by public officials submitted to the Saber Pungli BIBLIOGRAPHY Task Force established under Presidential Becker, G.S. (1968). Crime and Punish- Regulation (Perpres) 87 of 2016 concern- ment: An Economic Approach, ing the Clean-Sweep Illegal Levies Task Journal of Political Economy. [Ac- Force. It performs three types of actions: cessed from through special crime measures (Corrup- https://feb.ugm.ac.id/en/research/lec tion), general crime, or through an admin- turer-s-article/artikel-dosen/826- istrative process by returning unscrupu- penegakan-hukum-dan-pencegahan- lous perpetrators to the relevant agencies. tindak-kejahatan-dalam-tinjauan- These enforcement factors see the size of ilmu-ekonomi on 14 March 2020]. the cost of the losses incurred by the per- David D. Friedman. (1993). “Should the petrators of illegal levies. Law enforce- Characteristics of Victims and ment through this process is in line with Criminals Count? Payne v Tennes- the theory of cost and benefit analysis see and Two Views of Efficient Pun- which states that losses due to criminal ishment”, Article in Boston College acts and costs that must be incurred by Law Review, Vol. 34. law enforcers to deal with criminal acts Halim. (2004). Pemberantasan Korupsi. turned out to be greater than the number Jakarta: Rajawali Press. of profits derived by perpetrators from Mahmud Mulyadi. “Pungli: Antara Suap committing a criminal act, therefore the Atau Pemerasan”, Paper in the Pan- optimization of law enforcement will not el Discussion with the Topic: be realized. Perbedaan Suap dan Pemerasan? The advice that can be given is that Dan Akibatnya terhadap Kemu- the handling of an action that is included dahan Berusaha di Indonesia. Sura- in a criminal act does not have to always baya, 04 March 2019. be in the court domain. Crime as ultimum Mahrus Ali. (2008). Penegakan Hukum

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Pidana Yang Optimal (Perspektif Satjipto Raharjo. (2009). Penegakan Analisis Ekonomi Atas Hukum). Hukum Sebagai Tinjauan Sosiolo- Jurnal Hukum Nomor 2 Vol. 15, gis. Yogyakarta: Genta Publishing. Yogyakarta: UII. Anonym. https://saberpungli.id/tentang, Drafting Center for the Expertise of the [Accessed on 03 March 2019]. House of Representatives of the Re- Ano- public of Indonesia. Guidelines for nym.http://kabar24.bisnis.com/read/ Legal Drafting in Legislation. [Ac- 20171112/16/708273/ott-saber- cessed from www.dpr.go.id on 28 Febru- pungli-dalam-setahun-1.316-kasus- ary 2020 and 14 April 2020]. ditangani [Accessed on 30 January 2018].

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