CRIMINAL VICTIMIZATION ON LARGE-SCALE INVESTMENT SCAM IN INDONESIA

Mass scale investment fraud (Ponzi) schemes result in protracted suffering for the victims. In this article the author investigates this crime from a juridical normative, case, and conceptual approach. From the very start potential victims may fall to promises of lucrative and safe investment schemes. In the eyes of the more prudent, it would or should be obvious that the collaborative business offers as presented contains logical flaws, running against common sense and is at the outset illegal. Notwithstanding, victims seems to fall easily into this trap, lured by the promise of getting easy, quick, and huge investment returns. In the end, even when this fraudulent investment scheme unravels, the government of law enforcement seems to be unable to act decisively and offer a satisfactory solution. Slow and ineffective government response in the end exacerbate economic loss and victims suffering.


Introduction
Fraud or scam simply relies on the concept of cheating, deception, or dishonesty in obtaining profits on the one hand and/ or damaging others. Sticking to the concept, fraud will cover various types of acts, ranging from embezzlement, extortion, money laundering, corruption in the misuse of assets and various other financial crimes. 1 This concept of fraud will also refer to various violations of criminal offences, including violations of regulations in Indonesia. Apart from the concept of fraud and various related criminal offenses, the study in this article would like to focus on investment scams that result in victims and losses on a large scale. Based on its generic characteristics, the perpetrators in this modus are corporate owners or business perpetrators which are responsible for business relations with a large number of customers/investors. The perpetrators optimistically and creatively will offer an investment opportunity in certain business or project activities that tend to be unique and very profitable. 2 Perpetrators of investment scam will certainly succeed in collecting large funds/assets from investors by hiding the original situation of business activities in the investment scheme offered. In reality, these business activities could be designed as sham business ventures, which means that the promised business/ project activities never exist. 3 The perpetrators design a company and business activities that appear to be legitimate, registered with the relevant authorities, have legitimacy of establishment and operation based on regulations. After the funds are collected, the perpetrators immediately take off the funds and try to disappear without leaving a trace. For the sake of eliminating this trace, the perpetrators usually form a shell company in state jurisdictions that provide tax haven or secrecy jurisdiction facilities. Moreover, investment scamsters may indeed carry out real business activities, but these business activities will never be able to run as expected because they use forbidden schemes such as Ponzi 1 schemes. 4 This scheme is prohibited and identified with certainty as investment scam because sooner or later it always leads to loss and bankruptcy. 5 In Indonesia, investment scam cases have repeatedly occurred and according to the characteristics described, victims of crime can be recorded in the hundreds of thousands of people with losses reaching billions of up to trillions of rupiahs. One example is a case of an investment scam committed by the founder and management of a koperasi (Indonesian cooperative business) named KSP Pandawa Mandiri Group. This cooperative runs micro-lending and investment activities to raise funds from the community with a promise of a 10% (ten percent) profit every month for one year and a multi-level marketing system. The cooperative operated from 2011 to 2016, chaos began to emerge because new customers' deposits were difficult to channel, while the corporation still had to return profits according to the agreement. Customers no longer receive the promised benefits, nor can they even withdraw their investment funds. These customers then report the case to the Financial Services Authority (Otoritas Jasa Keuangan) and the Police. 6 The perpetrators were subsequently examined and found guilty of banking crimes related to the collection of funds and money laundering as was the latest judgment in the Supreme Court of the Republic of Indonesia. The victim in this case was estimated at 39,068 people with an estimated loss of 3.32 trillion rupiah. 7 Based on study of victimology, the investment scam cases mentioned above place the victim in a distinctive position that is important to analyzed. This investment scam creates particular victimization characteristics that differentiate it from conventional fraud or other economic driven crimes. In investment scam or conventional fraud or other economic driven crimes, the victim's problems both begin with suffering in the form of material loss related to assets. In 4 Supra no. 2, p. 103. conventional fraud or other economic driven crimes, the victim's suffering can be recovered faster than investment scam, related to the characteristics of the victims that are small numbers, the amount of the losses are not diverse and not complex.
It is different with investment scam, the suffering of the victim does not stop at the material loss. These sufferings lead to a series of negative excesses, including but not limited to factors originating from the legal system in Indonesia itself. These negative excesses and sufferings in turn form a complex criminal victimization of the victim which will be explained in the following analysis. The study of criminal victimization is needed to answer the main problem in victims of the investment scam cases, so that on the subject of the problem, a criminal justice system can be formulated which is not only able to prosecute the perpetrators, but also to restore the rights of victims or at least not to degrade or even eliminate victim's rights to recover their losses. 8

Large-Scale Investment Scam Cases and the Factual Problem of Victims
Before crime victimization can be analyzed, it is important to identify several examples of investment scam cases in Indonesia. Examples of factual cases along with the presentation of the modus and scale of the number of victims and losses that occurred can be used as a basis for determining the profile of victims and the problems faced by victims.
The first case identified was an investment scam with the investment modus by the owner and management of the koperasi (Indonesian cooperative business) named Cipaganti Karya Guna Persada, which was carried out in the period between 2007 and 2014 in Bandung. The owner and cooperative management initially set up business entities in the form of cooperatives aimed at raising funds from the community to finance various cooperative business activities. Cooperative management raises funds to form a scheme of capital investment cooperation and management of business activities with the promise of periodic return of capital and profits as well as liability for losses if the business 8 James Dignan, Understanding Victims and Restorative Justice, Open University Press, New York, 2005, p. 23, 30-31. activities managed by the cooperative experience a loss as outlined in the deed of cooperation between the cooperative and the investors or partners. So that more and more potential investors are interested in including their capital in the cooperative, the principals print many brochures, recruit and provide bonuses for marketers who have succeeded in obtaining many investors or partners (multilevel marketing system). 9 In the case of Cipaganti's scam investment, the business activities of the actors described above are contrary to the provisions concerning to the cooperatives law (Undang-Undang Perkoperasian) and also do not obtain a permit according to the Banking Law which the perpetrator should have. Funds that have been collected from partners are in fact diverted or used for various other business activities established by the perpetrators with (not direct cooperative business activities), these funds also flow into the personal accounts of the perpetrators. In 2013, there were financial difficulties in the business activities of the perpetrators, then the cooperative was unable to pay profits and return the investors' funds. In the midst of the cooperative's financial difficulties, the perpetrators are even more aggressively encouraging marketing personnel to offer this cooperation program without providing honest and transparent information to investors about the circumstances and difficulties experienced by cooperatives in running their businesses. As a result, some investors continue to invest their fund in the cooperative. As a result, in the period between 2007 and 2014 the cooperative managed to raise around 4.7 trillion rupiah from 23,193 investors. 10 However, the perpetrators could not return 3.2 trillion rupiah of funds belonging to 8,738 investors or partners. The examination also showed that there were no financial reports, even income records on cooperative accounts obtained The second case, related to an investment scam committed by the management and founder of PT. Golden Traders Indonesia Syariah (GTI Syariah) in the period 2011 to 2013. This corporation was established in 2011 by foreign citizens and obtained permission from the Investment Coordinating Board (BKPM) to trade gold, but along with the change of business activities into investment, this corporation also positions itself as a Syariah-based management corporation (in accordance with Islamic legal principles). Change to PT. The Syariah GTI was even supported by halal certification and recommendations given by the National Syariah Council, the Indonesian Ulema Council (MUI), and witnessed by the then Speaker of the Indonesian Parliament. PT GTI Syariah in its business activities offers investment schemes in the form of physical gold.
Prospective customers are asked to purchase gold at a price higher than the market price, then each month the customer will get a certain profit of 1.5% to 2% and at the end of the investment period the money can be returned (buyback guarantee). PT GTI Syariah then also offers non-physical gold investment products, meaning that investors or customers do not hold the gold, only in the form of sales invoices. Customers who choose this type of investment are promised greater benefits, namely 4.5 percent per month for the 6-month program and 5.4 percent per month for the 12-month program. 12 In the case of GTI Syariah, high profit margins, halal certification and support from the Indonesian Ulema Council and the Speaker of the Republic of Indonesia Parliament are subsequently used as promotional tools for the corporation to attract as many investors or customers as possible. On promotional media such as corporation websites and brochures aimed at prospective customers, the name of the Chairman of the Indonesian Ulema Council, Chairman of the DPR at that time, complete with photos and signatures as evidence of support for the corporation's business activities. In fact, PT. GTI Syariah also 12 Karvarino, "Tipu-Tipu Investasi Emas Berkedok Syariah," Gatra, 2013, https://www.gatra.com/detail/news/25595-tipu-tipu-investasi-emas-berkedok-syariah, accessed March 20, 2020, 19:20 GMT+7. Noverius Laoli, "Dua Petinggi MUI Terseret Investasi Bodong GTIS .," Kompas.com, 2014, https://money.kompas.com/read/2014/09/12/090000126/Dua.Petinggi.MUI.Terseret.Investasi. Bodong.GTIS, accessed March 20, 2020 mentioned that MUI, the Speaker of the DPR and a ruling party politician owned a 10% stake and became a corporate advisor, which was later denied by related parties as incorrect. Meanwhile, the majority shares are still held by the management and its founder who are foreign citizens. Before entering Indonesia, the founder of this corporation also claimed to have owned a gold investment business network in a number of countries with a company called GTI International. In addition, this corporation also offers investment products in various media, including by implementing a referral system where every customer is asked to find other customers through multi-level marketing (MLM). 13 Customers who successfully obtain new customers will get a commission.
Until 2012, the corporation managed to raise up to 45 trillion rupiah from 18,000 members. In 2013, problems began to arise, many customers complained about this corporation to the Financial Services Authority and the police because they felt cheated by this corporation. According to the customers, the promised benefits did not get and the investment money was not returned. After many reports were made, the police conducted an inspection and ensured that the founders of this corporation had fled abroad with 10 trillion rupiah of money owned by the customers.
The third case is a case committed by the founder and management of a corporation in the form of a cooperative (koperasi) called KSP Pandawa Mandiri Group. This cooperative was founded by a porridge entrepreneur who previously managed to obtain profits from the business of lending to small traders. For this business activity that has been running, this entrepreneur then formed a savings and loan business and obtained a license as a cooperative from the ministry in 2011. The business activity which initially took the form of micro-credit distribution developed into investment activities in raising funds from the public.
Customers will be asked to sign an investment cooperation agreement with the promise of a 10% profit every month for one year. These funds are then played in a micro-credit scheme for traders in markets or food vendors in Jakarta, Bogor, Depok, Tangerang and surrounding areas with interest reaching 20% every month. To increasingly attract interest in prospective customers, this corporation also established a tiered marketing system with a pyramid pattern (multi-level marketing system). The corporation appoints leaders and gives them status according to the level of success in recruiting new customers. These leaders are also given the authority to manage funds from new customers. Based on a cooperation agreement that reached 1 million shares, the Pandawa Cooperative managed to get 569,000 customers with a total fund of Rp 2 trillion. 14 In 2016, chaos began to arise because new customers' deposits were difficult to channel, while the corporation still had to return profits according to the agreement. Customers no longer receive the promised benefits, nor can they even withdraw their investment funds. These customers then report the case to the FSA (Financial Services Authority/ Otoritas Jasa Keuangan) and the Police. The results of the FSA examination found that all investment cooperation agreements were not signed in the name of the cooperative but directly in the personal name of the founder of the cooperative. The collection of funds and investments carried out by the founder of this corporation were also declared unlawful because the interest offered was clearly above the interest rate set by Bank Indonesia and its legal entity did not obtain permission from the FSA. This report was then continued with the police, who then arrested the founder of the cooperative and 26 other perpetrators who collaborated with the founder of the Pandawa cooperative. The perpetrators also use the funds raised for personal interests ranging from the purchase of houses, land, motor vehicles and other valuables. Victims problems begin to arise when investment funds and benefits that should be obtained by victims cannot be returned by the perpetrators. Such problems are certainly faced by all victims of any crime that has economic motives or crimes against assets, including investment scams. losses, both in the form of loss of assets and profits that should be obtained from the use of these assets in the future.
However, in the case of a scam investment, the problem of this suffering continues when the victim has to deal with the loss recovery or restitution system.
This system must accommodate so many interests with calculations and distributions that are clearly not simple. In Indonesia, such problems become complex due to the legal system which in fact is unable to provide concrete  Pidana," Yuridika 33, no. 2, 260-289, p. 270, 2018. of recovery for the victim's losses. This problematic explanation has a positive correlation with the facts about criminal decision and the legal efforts made by the victim to recover their losses suffered in the previous cases. These facts can be described in the table as follows: access to justice, fair treatment and action other assistance for victims. Even though it is not an international instrument that has binding power through ratification, this declaration has been recognized as an important instrument which serves as the basis for fulfilling the obligation of recovery or reparation to victims. 32 Compensation and restitution are basically both a form of restitution for losses or burdens suffered by victims due to crimes committed. 33

Large Scale Investment Scam
As has been emphasized in the previous explanation that the problem of the victim's suffering does not stop when the crime has been committed or even when the perpetrator has been tried. The problem of victims continues in the overlapping and complex legal system for victim loss recovery. The existing system is built from regulations from various fields of law which are not limited to the criminal justice system, but also civil law and bankruptcy law.
The explanation above is proven in the cases that have been identified because until now the settlement of loss recovery has not been able to be carried out. This happened even long after the criminal case against the perpetrators of crimes had been decided with permanent legal force (final and binding) by the court. For example in the case of the KSP Pandawa. In this case there were two decisions relating to the perpetrator's assets confiscated for the victim. The Depok District Court (which was later strengthened by the Bandung High Court and Supreme Court Decisions) decided that the perpetrator's assets were confiscated by the State, while the Jakarta Commercial Court in the case of bankruptcy ruled that the perpetrator's assets were distributed to creditors (victims) who were entitled to be fair and balanced. The same thing happened in the case of First Travel. The assets of the perpetrators according to the court decision were also confiscated for the state, but on the other hand the victims also submitted an 32   However, the victim accepted the offer because of the fact that there was a very large promise of benefits, such as comparison between high profit and low capital ratio or being able to perform Umrah at a much lower cost compared to others. In addition, the victim accepts the offer due to marketing techniques carried out by the perpetrators such as the promotion of profits from schemes multi-level marketing and sales agents, or the influence of those who have a reputation and credibility in the eyes of the community who collaborate with the perpetrators, 38 Leah E. Daigle, Victimology: A Text/Reader, Sage Publication, Los Angeles, 2012, p. 1. 39 Arif Gosita, Masalah Korban Kejahatan Kumpulan Karangan, Akademika Presindo, Jakarta, 1993, p. 39. such as cooperation with MUI institutions in the case of the Syariah GTI or promotional cooperation with artists in the First Travel case.
The interaction between victims and perpetrators of crime that gives birth to criminal victimization is also supported by victimization factors (conditions that make it easier for someone to become a victim) from the aspects of the government and the existing legal system. The government, with all its supervisory powers, is unable to provide adequate instruments to detect, prevent or stop the crimes being committed as early as possible. For example, in the case of GTI Syariah, several state institutions such as the OJK and Bappepti, said that they were not authorized to supervise the business activities of GTI Syariah, because they did not fall within the scope of their authority. 40 Review 5, no. 2. 1-13, p. 8-10, 2016. including also with law enforcement officials. 41 In the first element, the impact of victimization consists of an impact on the victim directly, which means that victimization explains the specific forms of suffering or change experienced by the victim from an event that occurred (direct victimization), as well as the indirect impact experienced by parties other than the victim , which relates to victims (indirect victimization).
The direct impact of large-scale scam victims as criminal victimization is basically similar to other crimes. These direct impacts can generally be classified in several forms, namely physical impacts, emotional and psychological impacts, and economic impacts. Physical impact is the impact of victimization that affects the physical health of the victim, for example due to bodily injury, disability to the most severe is death. Emotional and psychological impacts are the effects of victimization that affect the health of the mind, emotions or mental health of the victim, for example feelings of anger, fear, humiliation, self-blame, prolonged sadness to depression, anxiety and post-traumatic stress disorder due to experiencing or witnessing crime as a terrible event.
Related to economic impacts, this can refer to many things, including direct economic losses such as loss of assets, damage to property or indirect economic losses such as loss of time to work, loss of ability to generate income, costs incurred for medical treatment, costs as a consequence of activities in the criminal justice system (being a witness for example), costs for carrying out legal efforts, including immaterial losses, i.e. decreasing the quality of life of victims. 42 In large-scale investment scam crime, the most prominent and certain impact of victimization experienced by every victim is the economic impact. This loss can be specified in various ways, but concretely it can be summarized in two ways, first the loss of assets. In the cases that have been identified, this loss is money that has been deposited as an investment in the case of Cipaganti, GTI Umrah. Second, the loss of costs incurred due to all arrangements or activities carried out by the victim due to the crime, starting from the beginning before the crime was exposed, an examination by law enforcement officials involving the victim, up to the verdict and management so that victims receive fulfilment of restitution. This arrangement or activity certainly makes the victims have to pay more costs, at least for their mobility.  27, no. 1, 36-54, p. 38-39, 2014. 45 According to the intereview with the victim. Persiana Galih "https: //nasional.tempo.co/read/645395/korban-cipaganti-ada-yang-cerai-stres-dantewas/full&view=ok" Tempo.co, 2015, accesed February 20, 2020, 18.15 GMT+7 " Jayadi Supriadin, "Depresi, Korban First Travel Asal Garut Meninggal Dunia," Liputan6.com, 2017, https://www.liputan6.com/regional/read/3072406/depresi-korban-first-travel-asal-garutmeninggal-dunia, accessed February 20, 2020 victimization or indirect victimization. 46 The impact on the people around these victims may vary. The form of the impact that arises is also classified the same as the form of a direct impact, except physical impacts such as the victims' family also feel the impact of economic losses because the victim's assets are also a source of livelihood for the family, or the victim's family can also experience emotionalpsychological impacts, such as fear, anger, sad, traumatized or even depressed also because of seeing the condition of the victim. Such impacts can also be felt by the families of victims in large-scale scam, especially economic impacts. Victims experience loss of wealth that varies and not a few large enough numbers that affect the financial situation of the family. The victim's assets can be a source of livelihood or savings for the victims' family.
The victims' loss recovery system, namely victims' restitution or compensation that is regulated by law, is usually aimed at restoring the direct impact of crime as the primary victimization of a crime. In Indonesia, the system according to the Law on Witness and Victim Protection (Indonesian Law No. 13/2006 andLaw No. 31/2014) accommodates 3 forms of restitution or compensation (both cumulative and alternative) that can be requested in an application made by victim, those are restitution/compensation for loss of or income (economic impact), restitution/compensation for losses arising from suffering directly related as a result of a crime (other direct impacts, for example on the family); and/or reimbursement of medical and psychological treatment expenses (physical, emotional, psychological health impacts). In the criminal justice systems of common law countries, such as the United States, Canada and Australia, the impact or loss of the victims is described by the victims themselves in a reports called victims 'victim impact statements' or 'victim impact evidence'.
The subsequent report is an important consideration for the judge in deciding the restitution of the victim. 47 In Indonesia, restitution is carried out primarily, 46 Supra no 38, p. 81, 166. 47 Shahrul Mizan Ismail, Halila Faiza, Zainal Abidin and Apnizan Abdullah, "Victim Impact Statement In Criminal Sentencing: Success Or Setback For The Criminal Justice Process?" Current Law Journal 8, 15-32, p. 26-27, 2017. according to the government implementing regulations (Indonesian Government Regulation No. 7/2018 andNo. 35/2020), the victim as an applicant for restitution/compensation must submit an application that not only contains a description of the actual loss suffered, but also attaches legalized evidence related to the loss. For example, related to restitution/compensation for the loss of wealth or income, the victim attaches evidence, such as, the proof of handover or transfer of funds to the perpetrator of the crime, the victim's salary slip or other assets that can be assessed by the appraiser. 48 Meanwhile, related to reimbursemen for medical or psychological expenses including the depression, trauma and so on, the victim must also attach evidence such as notes or invoices for payment of medication, healing or treatment The suffering includes obtaining negative stigma from the community, being ignored as victims by the community, covering media that is inappropriate or disturbing personal rights, not getting services or information as victims based 50  2. In terms of time, the issue of legal certainty as explained earlier has logical implications for the sufferings of other victims, one of which is related to the time of fulfilment of victims' restitution. The existence of legal certainty space issues causes the legal system to be slow to work and slow to respond to any legal efforts made by the victims. For example, if one group of victims submits a legal effort for a lawsuit and another group submits a request for bankruptcy, then there is the possibility of the judge delaying the claim and the request on the grounds of awaiting criminal justice proceedings. However, when the criminal justice process was completed, it appeared that the judge had not yet decided on anything related to the fulfilment of victim's loss recovery. So, the victims need more time to continue or take other legal measures so that the loss can be recovered. Another example relates to the distribution of assets of perpetrators of crime. If the perpetrators are unable to pay the victims 'losses, then legal action will be taken against the perpetrators' assets such as confiscation, seizure and auction. These actions can be carried out on every legal effort taken by the victims, regardless of the nomenclature of the action. If these actions are mutually determined and overlap with some or all of the same assets owned by the perpetrators of crime, then the authorities or authorities cannot immediately take action and execute the assets of the perpetrators. Officials or authorized institutions must coordinate and other concrete settlement actions, or the authorized officials or apparatus only wait for one another without any certainty of execution of the determined actions.
In the end, this slow-working and slow-response system causes victims to suffer by waiting a very long time so that their losses can be recovered, or even not infrequently victims will not even receive any restitution.
3. In terms of the value of assets, the suffering of the time experienced by the victim brings the consequences of subsequent suffering to the value of assets as an economic loss for the victim. Based on the principle of time value of money (the time value of money), then the value of money today is worth more than the value of money in the future. This happens because of the effect of inflation (rising costs) and the reduced value of the money. Therefore, if the VeJ Volume 7 • Nomor 1 • 25 calculation of the value of the economic loss suffered by the victim remains (unchanged), then this value will actually decrease over time. The longer the victim waits for the fulfilment of restitution, such as payment of money, the more the value of the money decreases. For example, one of the victims of fraud suffered an economic loss of Rp. 20 million. If the victim has to wait 3 years to receive fulfilment of the restitution, then Rp. 20 million is actually not the same value compared if the victim received Rp. 20 million in the first or second year. Not only based on these principles, the suffering of victims can also be seen from the value of the benefits of fulfilling the restitution. The faster the victim receives the fulfilment of the restitution, the faster the victim can feel the benefits of fulfilling the restitution, for example the victim can immediately use the restitution money for working capital, or to finance family needs and so on. Thus, the suffering of the victims continues to decrease the value of the assets and delay the benefits of these assets.
The explanation of the suffering of the victims above shows that the victims have experienced secondary suffering or suffering for the second time besides the basic suffering as a direct result of crime. These sufferings are the main consequences of the complexity and overlapping of rules related to legal efforts to fulfil recovery that victims can take, including the absence of resolving norms, which in turn has an impact on the response of officials and authorities in the implementation of efforts to fulfil this restitution. Based on this understanding, it can be concluded that the system of fulfilling losses related to the victims of largescale scam in Indonesia today actually forms a secondary victimization of the victim. Victimization that occurs due to problems or negative excesses of the legal system for handling the victims themselves. The series of explanations ranging from the nature of criminal victimization, elements, impacts, to forms of victimization on large-scale scam crimes including the suffering suffered by victims can be understood in a criminal victimization scheme as follows: The problem with the large-scale scam investment victims' loss recovery system in Indonesia, which amounts to the form of juridical victimization and secondary victimization requires immediate formulation of resolution. The solution to this must target directly the main problem regarding the complexity and overlapping of regulations relating to legal remedies for the fulfillment of loss recovery, so that law enforcement officials and government are able to quickly and correctly respond to the task of fulfilling the right of the victims.

Conclusion
The victimization of large-scale invesment scam was formed due to one probable factor, spesifically activities to collect or withdraw large amounts of funds from the public (community) as a modus operandi of the crime. Large funds and resources that come from many members of the community, if misused, will form a distinctive victimization, which is diverse and great suffering for many victims. This victimization is then divided into 3 consecutive elements. The first element is primary victimization, which mainly consists of economic impacts accompanied by emotional, psychological and physical health impacts. The second

Economic Impact
Victims lose property and must incur costs for activities related to the justice system and recovery efforts.

Emotional-Psychological Impact
Feelings of anger, trauma to depression.

Physical Health Impact
Depression because being victims of scam can affect the physical health of victims, even some of which lead to death.

Social Impact
Victims change their job or lifestyle.

Consequential Impact
Victims change their mindset and behavior towards certain things (investment, travel services, etc.)

Juridical Impact
Victims make various legal efforts to restore their rights.

Juridical Victimization
1. Violation of the right to guarantee legal certainty of the victim. 2. A system that is slow to work and responds slowly resulting in victims having to wait a long time, for their rights to be restored, or even never to be restored until the victim dies. 3. Impairment of assets and postponement of benefits due to a slow or even non-working recovery system. element of victimization, the impacts that arise as a victim's self-reaction include social impacts and consequential impacts such as changes in work, lifestyle, mindset and behaviour related to investment The third element of victimization can be studied on the problem of the loss recovery system for victims of largescale invesment scam in Indonesia. The loss recovery system that exist in Indonesia currently creates secondary victimization of victims. Victimization occurs due to problems or negative excesses of the legal system for handling the victims themselves (juridical victimization). Facing such victimization problems, an integrative criminal policy is needed that is able to integrate various victim's loss recovery regulation, accompanied by detailed and rigid technical measurements with a certain period of time.