Can Export Leakages Really Be Sealed?

The export of strategic commodities leaves a significant data trail. The volume of goods is recorded in the Export Goods Notification (PEB), quality is inspected by surveyors, ships have travel logs, destination countries record import values, and transaction proceeds should return as export proceeds (DHE). The issue is that as long as this data is scattered across various systems and not read as a single complete transaction, the potential for discrepancies remains difficult to detect.

PT Danantara Sumberdaya Indonesia (DSI) is now using eight analytical use cases to identify and monitor potential underinvoicing, transfer pricing, and even DHE repatriation in strategic export commodities. In the initial phase, the system covers coal, oil palm or CPO, and ferroalloy.

These eight checks essentially attempt to view exports from three perspectives. First, the goods shipped, through reconciliation of quantity, quality, and Harmonized System (HS) codes. Second, the transactions that occur, by comparing declared prices, trade data from destination countries, affiliated parties, and the actual ship routes. Third, the flow of money, through reconciliation of incoming DHE with transaction values based on PEB.

This approach is important because discrepancies are not always visible from a single document. An apparently low export price, for instance, does not automatically indicate underinvoicing. Differences in quality, contract timing, product type, shipping costs, or transaction characteristics can affect export values. Therefore, the strength of the analytical system lies in its ability to match various indicators simultaneously before a transaction is deemed necessary for further examination.

DSI itself emphasizes that its role is to obtain data, verify and analyze transactions, and then report when indications of discrepancies are found. Follow-up actions remain with the ministries or agencies that have authority. This means the system does not automatically classify a transaction as a violation but functions as an early detection mechanism to narrow down the scope of unreasonable transactions.

This data integration is also a crucial part of export monitoring. The DSI system connects data from Customs and Excise, the Ministry of Trade, the Ministry of Industry, the Ministry of Energy and Mineral Resources (ESDM), and other agencies to match various transaction information. During the trial period, the government also reported that previously significant data discrepancies began to narrow after using comparative indices.

However, the measure of the system's success should not stop at how many transactions are indicated as anomalies. More importantly, it is about how many indications can be verified, the value of corrections produced, how quickly the examination process is conducted, and whether the monitoring can proceed without hindering legitimate exports. The principle of non-disruption is important to ensure that strengthening oversight does not add obstacles to ongoing normal contracts and trade relations.

Ultimately, analytical systems like the one developed by DSI can narrow the scope of export leakage by connecting data on goods, transactions, and foreign exchange more comprehensively. However, the existence of such a system does not automatically close all gaps. Its effectiveness still depends on data quality, verification accuracy, inter-agency coordination, and follow-up on detected indications. Therefore, the main challenge is not only to detect unreasonable transactions but to ensure that every anomaly can be proven and acted upon without hindering legitimate trade.