The oil and gas sector known as migas in Indonesian is one of the strategic industrial sectors that is considered vulnerable to corrupt practices. This is proven by the results of the corruption perception survey in 2015 by Transparency International, which ranks oil and gas in third place after the construction and services business, as the business sector that has the largest percentage of bribes. Nevertheless, the oil and gas industry and the mining and forest sectors have the highest prevalence (intensity level) at national and local levels. In other findings at the end of 2014, The Organization for Economic Co-operation and Development (OECD) released a report that is stating the extractive or natural resource exploitation industries such as oil and gas were the most corrupt industries in the world. The OECD Foreign Bribery report showed that 19% of 427 corruption cases in 2014, came from the extractive industry sector and 23 % of the 176 cases prosecuted under the Foreign Corrupt Practices Act (FCPA) came from the oil sector.

1. 1 www.pwypindonesia.org
Maret 2018
www.pwypindonesia.org
Policy Brief
Oil and Gas Industry & The Challenges
of Corruption Prevention in Indonesia
1) Program Manager of PWYP Indonesia
2) Member of Legal Drafter ‘Oil and Gas Law Revision’_Civil Society Version
3) National Coordinator of PWYP Indonesia
Author: Agung Budiono1
, Dessy Eko Prayitno2
, Maryati Abdullah3
Editor and Reviewer: Maryati Abdullah
The oil and gas sector known as migas in Indo-
nesian is one of the strategic industrial sectors
that is considered vulnerable to corrupt practic-
es. This is proven by the results of the corruption
perception survey in 2015 by Transparency In-
ternational, which ranks oil and gas in third place
after the construction and services business,
as the business sector that has the largest per-
centage of bribes. Nevertheless, the oil and gas
industry and the mining and forest sectors have
the highest prevalence (intensity level) at nation-
al and local levels.
In other findings at the end of 2014, The Organ-
ization for Economic Co-operation and Develop-
ment (OECD) released a report that is stating the
extractive or natural resource exploitation indus-
tries such as oil and gas were the most corrupt
industries in the world. The OECD Foreign Bribery
report showed that 19% of 427 corruption cases
in 2014, came from the extractive industry sector
and 23 % of the 176 cases prosecuted under the
Foreign Corrupt Practices Act (FCPA) came from
the oil sector.
This policy brief is developed by the National Sec-
retariat together with members of Publish What
You Pay (PWYP) Indonesia coalition to highlight
the corruption loopholes and practices that can
occur along the oil and gas extractive industries
value chain. This policy brief examines aspects
of corruption from various research sources, re-
ports, and court decisions, and case studies that
have taken place in several countries, including
Indonesia. This policy brief was developed for
the purpose to provide policy recommendations
for preventing corruption loopholes that can oc-
cur along the oil and gas business chain, espe-
cially in Indonesia.
A. Oil and Gas in The National Economy
As a very strategic industry, the rules in the
oil and gas business in Indonesia are relatively
highly regulated compared to other industries.
Despite this, it still does not rule out the possi-
bility of corruption practices. This is supported
by the characteristics of the capital-intensive
oil and gas industry so that the value of money
circulation in the oil and gas sector is very high.
As an illustration data that reinforces this argu-
ment, data from Special Task Force for Upstream
Oil and Gas Business Activities (SKK Migas) has
mentioned the value of all commitments to the
procurement of goods and services, whether
done through SKK Migas approval or held by
a Joint Operating Body (JOB/KKKS), in Janu-
ary-December 2015, it reached US$ 6.519 billion

2. 2 www.pwypindonesia.org
with a percentage of the Domestic Component
Level/Local Content (TKDN) of 64.49% (cost ba-
sis) (SKK Migas, 2016).
A long chain of oil and gas business, from up-
stream to downstream requires substantial infra-
structure support and involves actors and vari-
ous stakeholders, from the central government,
regional governments, KKKS including BUMN,
national private sector and multinational com-
panies (Multinational company-MNC), and also
business people in the upstream oil and gas
supporting industry chains such as supporting
the transportation needs of industry, pipelines,
business and investment consultants, catering,
banking, and so on. For example, the significant
role of the banking sector, the annual commit-
ment of payment transactions through BUMN/
BUMD banks from April 2009 to December 2015
is estimated at US$ 47,859 billion (SKK Migas,
2016).
State revenue from the oil and gas sector in 2015
is still dominated by the upstream oil and gas
business consisting of oil and gas income tax
(PPh), Oil and Gas non-tax state revenue (PNBP),
and other PNBP. The value reached US$ 12.86
billion or Rp177.47 trillion. This realization is still
the lowest in the last five years which is only
85% of the 2015 Revised State Budget (APBN-P)
target of US$ 14.99 billion. From the operational
side, petroleum production in 2015 was 777,560
barrels per day (bpd) or 94.2% of the target set
by the government of 825,000 bpd. As for gas,
production is also below the target of 6,933.27
billion British thermal units (BBTU) or 97.9% of
the target of 7,079 BBTU. Also, the cost recovery
charged from the Joint Operating Body (KKKS)
was recorded at US$ 13.9 billion or reached
96.8% of what was set at US$ 14.1 billion.
On the other hand, the significant contribution
of oil and gas in the national economy creates
dependency as well as vulnerability. The risk of
price fluctuation on crude oil in the international
market greatly impacts Indonesia’s trade balance.
The impact of falling oil prices will greatly affect
the level of state and regional income from sales
and revenue sharing from oil production (lifting).
While in the downstream sector, because Indo-
nesia is also an oil net importer, an increase in
oil prices could otherwise cause a deficit in the
national trade balance transaction, which will af-
fect fiscal spending for fuel subsidies and other
public sectors.
B. Corruption in The Oil and Gas Sector
To make it easier in dissecting corruption in the
oil and gas industry sector, traceability can be
carried out through the business chains and pro-
cesses of the industry (extractive value chain).
The oil and gas industry business chain starts
from the investment process in tendering a block
or oil and gas Working Area (WK), which is then
continued in the contract negotiation process,
the ‘deals’ process from the contents of the con-
tract to the field development and production
process, until the oil and gas block produces
and carries out a trade (trading) and aspects of
spending out of the oil and gas revenue stream
from the central to the local regions, to the vil-
lage and community levels and also in the pro-
curement of goods and services from the supply
chain to social expenditure.
In the broad sense, two main parties in each in-
dustry are the government and the private sec-
tor, hence corruption is largely determined by the
existence of supply and demand factors so that
the institutional design and its derivative regula-
tions will determine the presence or absence of
corruption.
The Center for International Private Enterprise
(CIPE) in its report entitled Overview of Anti-Cor-
ruption Compliance Challenges in The Oil and
Gas Sector -A Guide for Mid-Sized Companies
in the Oil & Gas Industry in Indonesia in 2015 said
that there were five key factors that trigger op-

3. 3 www.pwypindonesia.org
portunities for corruption. First, the ambiguity,
complexity, and business laws and regulations
often change. The absence of legal certainty
makes it difficult for business actors to adjust
and obey the rules so it triggers corruption.
Second, the lack of transparency and account-
ability, when agreements often occur “under the
table and closed” it becomes impossible for the
public to know whether the government and the
private sector truly represent the public interest
and respect existing laws or not. Third, a lack of
competition. Companies that monopolize busi-
ness and dominate the market with business
cartels usually have high incentives so that they
tend to deviate because government control is
strong and often monopolize (usually happens in
countries with strong government control - Indo-
nesia is not included).
Fourth, low wages, when government agencies
and their officials are unable to meet their dai-
ly needs through their salaries, they often com-
mit corruption to supplement their income from
regulatory loopholes that they understand. Fifth,
inadequate, inconsistent, and unfair enforce-
ment of laws and regulations. These factors of-
ten make the rules of the game ineffective. Even
though there is a law to eradicate corruption,
weak law enforcement can lead to misuse of the
system. The weak judiciary, prison sentence re-
duced, and high cost economy can make the law
ineffective.
Based on its business chain, oil and gas consists
of several sectors: upstream, middle stream and
downstream. Oil and gas sector business activ-
ities, from upstream business (exploration and
exploitation) to downstream business (process-
ing, transportation, storage, and commerce) are
regulated by Law Number 22/2001 on Oil and
Gas along with its derivative rules. Whereas oil
and gas revenue in the form of revenue-sharing
funds to the regions has been regulated at Law
4) Organization for Economic Cooperation and Development (OECD). (2016). Corruption in the Extractive Value Chain: Typology of risk, mitigation
measures and incentives. (http://www.oecd.org/dev/Corruption-in-the-extractive-value-chain.pdf)
Number 33/2004 on Financial Balance between
the Central Government and Local Governments,
and also Law Number 21/2001 on Special Auton-
omy for the Province of Papua, and Law Number
11/2006 on the Government of Aceh.
In May 2016, OECD released an instrument
(toolkit) named “Typology of risks, mitigation
measures and incentives in the extractive chain”.4
This tool specifically aims to mitigate corruption
in the extractive sector, particularly oil, gas, and
mining. This instrument comes from the evi-
dence-based analysis so how corruption works is
easier to understand. The report provides practi-
cal options for overcoming the risk of corruption
through collective action in the government and
private levels, which can be carried out in OECD
and non-OECD countries, extractive companies,
and civil society.
This instrument also produces typologies for
mapping out corruption schemes and vehicles
that are used to carry out corrupt practices. From
these findings, typologies show how illegal pay-
ments are disbursed, disguised through offshore
transactions, complex corporate structures, and
also often involve shell companies which make
it harder to detect and sanction corruptors and
their practices.
Corruption practices revealed include bribery of
foreign officials, embezzlement, misuse and mis-
appropriation of public funds, abuse of authority,
trading in influence, favoritism, and exploitation,
bribery of state officials and payment/providing
facilities. Based on the typology’s findings, cor-
ruption loopholes arise at every point along the
extractive value chain: from giving rights to ex-
tract, revenue stream, expenditure, and social
investment.
McPeherson and MacSearraigh (2007) have de-
veloped studies that dissect loopholes to cor-
ruption based on business chains (value chains),
which are classified in Table 1.

4. 4 www.pwypindonesia.org
Table 1. Corruption Loopholes Based on Oil and Gas Business Chains and Examples in Indonesia
Business Chain
in The Oil & Gas
Industry
Corruption Prone Area Warning Sign Recommendation
For Example
in Indonesia
Exploration • Policy Formulation
• Law, Contracts, Fiscal
Term
• Licensing/Contract
Awards)
• Permits, Approvals
• Lack of policy clarity
• Opaque, incomplete
legal, fiscal frame-
work
• Direct, non-trans-
parent negotiation of
licenses
• Unbalanced, “odd”
Award
• Delays on permits
approvals
• Clear, publicly an-
nounced policies
• Best practice legal, fiscal
framework
• Transparent, simplified
bids for license awards,
published results
• Transparent public
reports on permitting
approvals
Licensing case
regarding allocation
natural gas usage
involved Sampang’s
regent
Development and
Production
• Permit, approvals
procurement
• Theft of production or
revenues
• Permitting delays
• Limited international
competitive bidding
• Non-transparent bids
• “Odd or repeat pro-
curement awards
• Rumours of abuse
• Aggressive local con-
tent rhetoric
• Volume discrepancies
• Absence of metering
• Transparent, competitive
procurement
• Publication of results
• Credible channels for
complaint or challenges
• Regular volume audits
and reconciliations
Trading and Trans-
port
• underreporting of
value or volume
• Illegal rent extraction
for infrastructure
access
• Prices below refer-
ence benchmarks
• Volume discrepancies
• Opaque or lack of
reporting on sales
• Unusual reliance on
middleman
• rumors of abuse
• Queues for access to
infrastructure
• Full transparent reporting
of trades, sales
• Transparent bidding for
selection of middleman
• Regular audit of sales
• Volume audits, reconcil-
iations
• Transparent public rules
and tariffs for infrastruc-
ture access
• Appeal, complaint pro-
cedure
The case of crude
oil trader auction
involved Head of SKK
Migas, Rudi Rubi-
andini
Refining and Mar-
keting
• Downstream policy
formulation, such as
price control
• Black marketers,
smuggling
• Product adulterations
• Product procurement
• Price control
• Non-transparent
product procurement
• Queues for product,
product shortages
• Policy clarity
• Price liberalization-trans-
parent allocation of
proceeds
• Competitive transparent
tendering)
Alleged case of fuel
price cartel; Multilevel
trader of natural gas
distributors

5. 5 www.pwypindonesia.org
Corporate Ac-
counting and
Finance
• Inaccurate reporting
• Tax evasion
• Diversions of funds
• Money laundering
• Limited transparency,
secrecy
• Tax immunity or
unusually low tax
burdens
• Inadequate audit
• Full, transparent publi-
cized audits
• Qualified, independent
tax and cost audits
The findings of the
BPK on allegations
of deviations from
cost recovery funds,
despite a debate
between SKK Migas
and BPK
Source: McPeherson and MacSearraigh (2007) and PWYP Indonesia data compilation.
C. How Oil and Gas Corruption Loopholes in Indonesia?
5)Robby Irfani. (2015). KPK: Ini 13 Titik Rawan Korupsi Usaha Hulu Migas. (Mei 21, 2015). (https://bisnis. tempo.co/read/668224/kpk-ini-13-titik-
rawan-korupsi-usaha-hulu-migas)
6) Komisi Pemberantasan Korupsi. (2015). Laporan Tahunan 2015. (https://www.kpk.go.id/images/Annual%20Report%202015%20low.pdf)
In the leadership of the Minister of Energy and
Mineral Resources, Sudirman Said, the issue of
the oil and gas mafia seized public attention. Alle-
gations of state losses of up to trillions of rupiahs
made Sudirman form an Oil and Gas Governance
Reform Team (TRTKM). The public and the media
often refer to that team as the Anti-Mafia Oil and
Gas Team. The team consists of several experts
in the oil and gas sector and is chaired by Faisal
Bashri, an economist at the University of Indo-
nesia. The team has four main tasks including
reviewing the entire licensing process from up-
stream to downstream; restructuring institutions
related to oil and gas management; accelerate
the revision of the Oil and Gas Law; revise the
entire business process to prevent ‘rent seeking’
in every oil and gas industry.
There are at least 12 (twelve) recommendations
with 26 (twenty-six) derivative points in the TRT-
KM report that discusses upstream, midstream
to downstream sectors. 40% of them are recom-
mendations that seek to close the loopholes of
state losses due to corrupt practices in the oil
and gas sector. One of the main highlights is Per-
tamina’s oil trading company, Petral. The subsid-
iary of PT Pertamina is considered ‘controlled’ by
the oil and gas mafia, especially in the procure-
ment of crude oil imports.
The Corruption Eradication Commission (KPK)
has conducted a study and mentioned that there
are 13 (thirteen) corruption-prone points in the
oil and gas business chain. At the exploration
stage, the point that is vulnerable to corruption
practices is in the determination of potential
oil and gas areas, cooperation contract agree-
ments, licensing processes, approval of the plan
of development (POD), approval of the work plan
and budget (WPB), approval process of author-
ization for expenditure (AFE), and approval pro-
cess the procurement plan. KPK also considered
the exploration supervision stage is vulnerable to
deviation. Meanwhile, at the exploitation stage
corruption is vulnerable to occur in the process
of assets control and cost of production control,
mainly cost recovery control in investment credit
and interest recovery.5
KPK in its 2015 report stated that in 2008 the KPK
conducted an assessment of oil and gas man-
agement by BP MIGAS (currently SKK Migas),
one of the recommendations was that BP Migas
develop a monitoring system based on integrat-
ed information and technology systems so that
data can be known primary production at each
KKKS and their mutations at any time accurately.
SKK Migas developed an information system to
support the integration and management of data
related to KKKS operational activities, namely the
Integrated Operations System (SOT). The SOT
infrastructure has been implemented 100% but
the completeness and accuracy of the SOT data
in quarter IV-2015 has not reached 100% (43% of
oil and condensate cooperation contract/KKKS
and 45% of gas cooperation contract), so it is
considered not implemented yet.6
At present, the

6. 6 www.pwypindonesia.org
KPK has also taken further precautions through
Coordination and Supervision in the energy sec-
tor.
In addition, KPK in the 2014 report also explained
the results of studies in the downstream oil and
gas sector. The scope of the study touches on
the whole business process comprehensively,
related to the governance of the state’s share of
7) Komisi Pemberantasan Korupsi. (2014). Laporan Tahunan 2014. (https://www.kpk.go.id/images/pdf/laptah/Laporan%20Tahunan%20KPK%20
2014.pdf)
gas sales, related to the Gas Sale and Purchase
Agreement (PJBG) which is allocated and non-al-
located; tolling agreement of condensate pro-
cessing between PT Pertamina and TPPI; trans-
port and trade governance, which until now has
not been clearly revealed. The important finding
is that there are no guidelines for oil and conden-
sate sales in the interior of PT Pertamina (Per-
sero).7
D. Case Study of Corruption in The Upstream
and Downstream Sectors
The Case of Rudi Rubiandini (Upstream Sector)
Former Chairman of SKK Migas, Rudi Rubiandini, was sentenced to seven years in prison and
fined Rp 200 million (two hundred million rupiahs) in a three months prison sentence by the
court council. Rudi was found guilty of committing corruption and money laundering (TPPU)
together as the first primary in the indictment, Article 12 letter a, second indictment, Article 11
of the Corruption Act, and third indictment Article 3 of the TPPU Law in conjunction with Arti-
cle 55 paragraph (1) jo Article 65 paragraph (1) of the Criminal Code. The verdict was stated in
the trial at Central Jakarta State court with Number 85/PID.SU/TPK/2013/PN.JKT.PST in 2014.
Based on the facts and evidence at the trial, the court council considered that Rudi was prov-
en to receive money directly or indirectly through Deviardi. Rudi received US$ 900 thousand
(nine hundred thousand United States dollars) and Sing$ 200 thousand (two hundred thou-
sand Singapore dollars) from the owner of Kernel Oil Pte Ltd, Widodo Ratanachaitong for the
interests a sum of Widodo companies in an auction at SKK Migas.
After Deviardi gave money US$ 300 thousand (three hundred thousand US dollars) from
Widodo to Rudi at the Plaza Mandiri Building, Rudi gave US$ 200 thousand (two hundred
thousand United States dollars) to the Chairman of the House of Representatives Commis-
sion VII Suthan Batoegana through Tri Yulianto. Then, Rudi was proven to have received US$
522.5 thousand (five hundred twenty-two thousand five hundred United States dollars) from
the President Director of PT Kaltim Parna Industri (KPI), Artha Meris Simbolon. The Assembly
said that the gift of money from Artha was intended for Rudi to recommend a reduction in the
gas price formula of PT KPI to the Minister of Energy and Mineral Resources (ESDM).
In addition, Rudi was proven to receive money from several SKK Migas officials sum of Sing$
600 thousand (six hundred thousand United States dollars) from Deputy Head of SKK Migas
Yohanes Wijanarko, US$ 200 thousand (two hundred thousand United States dollars) from

7. 7 www.pwypindonesia.org
Deputy of SKK Business Support Control Migas, Gerhard Rumesser, and US$ 150 thousand
(one hundred and fifty thousand United States dollars) from the Head of the SKK Migas Op-
erations Support Division, Iwan Ratman.
In the judicial consideration, Anwar, judge member, explained that Deviardi was contacted by
Iwan Ratman to come to his house in Kemang in January 2013. For expressing gratitude, Iwan
gave Rudi money in the amount of US$ 50 thousand (fifty thousand United States dollars).
Deviardi handed over the money to Rudi. However, Rudi asked Deviardi to keep it. In February
2013, Rudi asked Deviardi to meet Johanes Widjanarko in his office. Johanes gave Deviardi an
envelope containing Sing$ 600,000 (six hundred thousand Singapore dollars). Rudi opened
the envelope given by Johanes when he was on the way home and he found six white enve-
lopes which each of them contained money as much as Sing$ 100,000 (one hundred thou-
sand Singapore dollars).
Rudi asked Deviardi again to meet Gerhard Rumesser. From Gerhard, Deviardi received an
envelope that contains US$ 200 thousand (two hundred thousand United States dollars) for
Rudi. At the request of the Secretary-General of the Ministry of Energy and Mineral Resourc-
es, Waryono Karno, Rudi gave US$ 150 thousand (one hundred fifty thousand United States
dollars) from Gerhard for the needs of the Ministry of Energy and Mineral Resources in the
framework of the 2013 APBN-P meeting. According to Anwar, Deviardi always reported the
gifts to Rudi. After Deviardi reported, Rudi asked Deviardi to save the money. At Rudi’s direc-
tion, Deviardi kept his safe deposit box at CIMB Niaga Bank. The Assembly concluded all the
gifts were made known by Rudi.
The Case of Fuad Amin (Downstream Sector)
The sentence for Fuad Amin, the former Regent of Bangkalan was increased to 15 (fifteen)
years reduced by the detention period and fined three billion rupiahs in subsidiary punish-
ment for 11 (eleven) months of confinement. This was stated based on the verdict of the Ja-
karta High Court with decision number 43/PID/TPK/2015/PT.DKI. Previously, in the decision
of the Central Jakarta District Court, Fuad Amin was sentenced to 8 (eight) years in prison
minus a prison term, fined one billion, and punishment subsidiary for 6 (six) months.
Fuad’s sentence was added after the council committee rejected the appeal. Fuad was prov-
en corrupt when he served as regent of Bangkalan regent, he was carrying out money laun-
dering. The verdict on Fuad was handed down on February 3, 2016, by Chief Justice, Elang
Prakoso Winowo.

8. 8 www.pwypindonesia.org
D. Policy Recommendation
To close the potential corruption loopholes in the oil and gas sector, PWYP Indonesia coalition formu-
lated several policy recommendation points, as follows:
Clarity and consistency of oil and gas sector regulations, from upstream to down-
stream. Clarity and consistency of regulations can create legal certainty in the oil and
gas industry that will foster stakeholder confidence and close bribery loopholes and
other forms of corruption as a result of vague or non-transparent regulatory loopholes.
Transparent, simple and non-volatile regulations provide certainty in the procedures and
stages of the oil and gas industry business process for businesses, investors, and make
it easier for community stakeholders to control the implementation of regulations for the
oil and gas industry, so it will not violate laws and public rights extensively.
Transparency and accountability throughout the oil and gas business chain. Transpar-
ency and accountability must be ensured throughout the oil and gas industry processes,
from the exploration stage, field development and production, trade and transportation,
processing, and marketing downstream, state income tax, profit-sharing funds by fol-
lowing financial and accounting and reporting. Transparency of public data and informa-
tion requires supervision and law enforcement from the government, the public and law
enforcement. Transparency and accountability should ensure public participation in the
governance process of the oil and gas industry.
1
2
During his time as Bangkalan Regent and Chairman of the Bangkalan DPRD, it is said that Fuad
received money that is to be suspected of corruption related to his position because he was
receiving money as much as Rp18.05 billion (eighteen billion point zero five rupiahs) from the
boss of PT MKS, Antonius Bambang Djatmiko.
Bribery was given by Bambang so that Fuad, who was the Regent of Bangkalan, can simplify
an agreement on a consortium of cooperation between PT MKS and PD Sumber Daya, as
well as providing support for PT MKS to Kodeco Energy related to the request for natural gas
distribution to East Gili.
Fuad was also charged with money laundering by transferring his assets to several bank ac-
counts. There are also purchases of assets in the form of land and buildings and cars in the
name of Fuad’s wife and children. During the trial, it was revealed that Fuad used a different
identity to open several bank accounts.
Besides using an identity with his name, Fuad also uses the identity of others in opening bank
accounts to store his assets. Fuad borrows someone else’s identity card, and takes the per-
son to the bank. Then, he submits an identity card in the person’s name to open an account
so all account books and ATM cards are controlled by Fuad.

9. 9 www.pwypindonesia.org
Transparent and competitive procurement processes of oil and gas industries. The
procurement process in the auction block/oil and gas Working Area in the initial phase;
procurement of goods and services in field development as well as exploration and pro-
duction; procurement in sales, transportation, and marketing; and procurement in the
downstream sector, and marketing must be done transparently and competitively so that
the loopholes in corruption that are often followed by nepotism (conflict of interest) can
be closed and monitored.
Development of local content and economic multiplier effects that are participatory,
transparent and competitive. These can prevent monopolies, unfair competition, and
corruption in the supply chain of the oil and gas industry, from upstream to downstream.
It is also important to overcome economic inequality and create multiple impacts from
the oil and gas industry.
3
4
Comprehensive and consistent oversight and law enforcement of the oil and gas in-
dustry. These need to be done along the oil and gas business chain, from upstream to
downstream which requires consistent and comprehensive oversight and law enforce-
ment. For example, oversight of oil and gas production volume (lifting), sales and trans-
portation procurement, the determination of traders and intermediaries, price control,
tax compliance, payment of state revenue and profit-sharing to oil and gas producing
regions.
5

10. 10 www.pwypindonesia.org
References
McPherson,Charles, and Stephen MacSearraigh. (2007). Corruption in the Petroleum Sector.
Center for International Private Enterprise (CIPE). (2015). Overview of Anti-Corruption Compliance
Chal­lenges in The Oil and Gas Sector - A Guide for Mid-Sized Companies in the Oil & Gas Industry in
Indo­nesia.
Komisi Pemberantasan Korupsi. (2014). Laporan Tahunan 2014. (https://www.kpk.go.id/images/pdf/
laptah/Laporan%20Tahunan%20KPK%202014.pdf)
Organization for Economic Cooperation and Development (OECD). (2016). Corruption in the Extractive
Value Chain: Typology of risk, mitigation measures and incentives. (http://www.oecd.org/dev/Corrup-
tion-in-the-extractive-value-chain.pdf)
Tim Reformasi tata Kelola Migas. (2015). Laporan dan Rekomendasi Tim Reformasi Tata Kelola Migas.
Irfani, Robby. (2015). KPK: Ini 13 Titik Rawan Korupsi Usaha Hulu Migas. (Mei 21, 2015). (https://bisnis.
tempo.co/read/668224/kpk-ini-13-titik-rawan-korupsi-usaha-hulu-migas)
SKK Migas. (2016). Bahan Presentasi Kinerja Sektor Hulu Migas.
Transparansi International. (2015). Indeks Persepsi Korupsi Tahun 2015.
Komisi Pemberantasan Korupsi. (2015). Laporan Tahunan 2015. (https://www.kpk.go.id/images/Annu-
al%20Report%202015%20low.pdf)

11. 11 www.pwypindonesia.org
Policy Brief Oil and Gas Industry & The Challenges of Corruption Prevention in Indonesia is supported
by The Natural Resource Governance Institute (NRGI) through Indonesia Centre for Environmental Law
(ICEL). Content and Opinion are composed by the authors from the national secretariat together with
members of the Publish What You Pay Indonesia coalition and ICEL. All of the content writing does not
reflect attitudes and opinions from NRGI.
Translated by Wicitra Diwasasri
Design and layout by Abdun Syakuur
Jakarta, Policy Brief, Edisi Maret, 2018
Hak Cipta Dilindungi oleh Undang-Undang.
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www.pwypindonesia.org — Website
Address
Jl. Dempo II No.21, RW.3, Gunung, Kec. Kby.
Baru, Kota Jakarta Selatan, Daerah Khusus Ibu-
kota Jakarta 12120
Contact
info@icel.or.id — Email
www.icel.or.id — Website
Publish What You Pay Indonesia
[Yayasan Transparasi Sumberdaya Ekstraktif]
Indonesia Centre for Enviromental Law (ICEL)
Social Media
icel_indo — Instagram
icel_indo — Twitter
Indonesian Center for Environmental Law — Facebook

12. 12 www.pwypindonesia.org
PWYP Indonesia is a coalition of civil societies for transparency and accountability of extractive
resource governance in Indonesia. PWYP Indonesia was established in 2007, legalized under
Indonesia’s law in 2012 as Yayasan Transparansi Sumberdaya Ekstraktif, and affiliates to the
network of PWYP global campaign. PWYP Indonesia works in transparency and accountability
along the chain of extractive resource, from development phase of contract and mining opera-
tion (publish what you pay and how you extract), production phase and revenue from industries
(publish what you pay), to the spending phase of revenue for sustainable development and
social welfare (publish what you earn and how you spent)