金融帳戶開戶與運作中所具有的身份信任-以台灣市場為例

Abstract

這是個充滿挑戰的時期，卻是對線上業務的黃金發展時期。在新冠肺炎(Covid-19)疫情中，所有的業務都受到影響，而人們也被要求儘量地採取非面對面的方式來完成各項活動。這篇論文起始於承平時期，但所試圖探究非面對面金融帳戶開戶的影響卻剛好與此非常時期我們所面對的挑戰具相關性。 或許這個世界不會，也無法再次回到從前我們所習慣的生活方式。而我們也觀察到，金融機構在逐步走向線上非面對面業務活動的過程中，許多風險仍舊是存在的。而這些風險，是否會因為非面對面業務的擴大，而伴隨更多涉及金融犯罪、洗錢與資恐的相關風險，則是我們所關切的。 透過對監管機構對KYC、CDD相關規定與期望的理解，進而比對金融機構的常見作為，我們希望能夠了解到是否在逐步演進到線上非面對面業務的過程中，是否有些事宜或議題成為了可能的阻礙與弱點，而導致金融機構對客戶的信任程度受到減損或挑戰，亦或是產生額外的風險弱點。希望透過這個過程，使我們在從面對面業務活動逐步走向非面對面業務活動時，得以有更好的準備而使其更完善。

This is a challenging time for all, despite being a golden age for online business. During the Covid-19 pandemic, many countries are facing lockdown and business activities have been down to an incredibly low level, low enough to make people wonder whether some of the damage is irreparable. People have been forced to stay at home and change their behavior in many ways. Working/studying from home is one of them, but most of all, “social distancing”, or reduced face-to-face activities, is that a central element of every government’s advice to their people. Things being done in a non-face-to-face manner is highly recommended, and more people have learned to do shopping online, ordering food online, keeping in touch online, and, of course, banking online. This paper was initiated at a time which was relatively peaceful (or at least much healthier), when banking digitally in a non-face-to-face manner was rather a trend than a necessity. However, when many of us would agree that “the world will not go back”, one of those things that will not go back is the trend of increase in non-face-to-face business activities. While we embrace the coming of the digital era, and are willing to try new non-face-to-face activities that should benefit ourselves and others, we see risks persisting. A lot of criminals are still leveraging financial institutions as a tool or conduit for money laundering: when it is already challenging for financial institutions to stop criminals starting business relationship with them under current mostly face-to-face process, will it become risker when we turn the account opening process to an online non-face-to-face process? In other words, can financial institutions maintain the same or even stronger confidence in customer identification when they switch their Know Your Customers (KYC) or Customer Due Diligence (CDD) process from paper-based face-to-face processes to online digital non-face-to-face processes? Thus, in this paper, we will firstly try to elucidate the core aspects of KYC/CDD, and then examine what the financial industry has done in reacting to the associated regulatory expectations. By comparing the differences between regulatory expectations and industry practices, we would like to raise challenges or concerns found during the process and provide suggestions for market participants to rethink what kind of risks should be addressed in order to sustain confidence in the KYC/CDD process. Hopefully, by addressing more risks, the journey for us to turn into a digital world will be a more fruitful and smooth experience.