October 2026
Taiwan FSC Amends the Regulations Governing the Deposit Accounts and Suspicious or Unusual Transactions: The Impact of Tighter Bank Account Controls on Foreign Workers
To prevent financial services from being exploited for criminal purposes, the Financial Supervisory Commission (“FSC”) promulgated amendments to the Regulations Governing the Deposit Accounts and Suspicious or Unusual Transactions (the “Regulations”) on August 31, 2026. The amendments broaden the range of deposit accounts that may be classified as accounts with suspicious or unusual transactions (“Suspicious Accounts”) and lower the threshold for banks to take action against them. Below, we focus on the circumstances under which a foreign national’s bank account may now be treated as a Suspicious Account and analyze the potential impact on foreign workers.
I. Key Amendments
A. New Categories of Suspicious Accounts
The amendments add five new categories of Suspicious Accounts, one of which concerns foreign nationals. Under Article 4, Subparagraph 2, Item 8 of the amended Regulations, a bank must verify and keep close watch on a foreign national’s account if the bank learns that the Alien Resident Certificate or other identification document that the account holder provided at account opening has been terminated before its expiration date, or that the account holder has overstayed or been reported missing.
B. Lower Threshold for Bank Action
Under Article 5, Subparagraph 2, Item 1 of the amended Regulations, once a bank concludes through verification and monitoring that a Suspicious Account may involve suspicious or unusual transactions, it may take appropriate measures against the account without first confirming any illegality. Appropriate measures include:
1. notifying a judicial police authority or other law enforcement authorities;
2. suspending all or part of the account’s transaction functions;
3. suspending the account’s ATM card functions, funds transfer by telephone or Internet, and other electronic payment functions; and
4. returning inward remittances to the remitting bank.
II. Impact on Foreign Nationals and Employers, and Our Recommendations
Once a foreign national’s employment in Taiwan ends, the basis for his or her lawful residence may cease to exist, in which case the National Immigration Agency will revoke the residence permit and terminate the Alien Resident Certificate (Article 31, Paragraph 4 of the Immigration Act). As a result, the foreign national’s deposit account may be classified as a Suspicious Account. The bank may suspend transactions, leaving the account holder unable to withdraw deposits or receive remittances and making the remaining balance difficult to handle. In addition, wages, severance pay, and other payments that an employer remits to a foreign worker’s Taiwan bank account after the worker’s departure may be returned under the Regulations and fail to reach the worker on time. This makes it harder for employers to settle all wages as required by law (Article 9 of the Enforcement Rules of the Labor Standards Act), or to issue severance pay on time (Article 17, Paragraph 2 of the Labor Standards Act).
To avoid labor-management disputes arising from restrictions on a foreign employee’s bank account, we recommend that employers of foreign nationals review their offboarding procedures and payment arrangements for departing foreign employees in advance.
I. Key Amendments
A. New Categories of Suspicious Accounts
The amendments add five new categories of Suspicious Accounts, one of which concerns foreign nationals. Under Article 4, Subparagraph 2, Item 8 of the amended Regulations, a bank must verify and keep close watch on a foreign national’s account if the bank learns that the Alien Resident Certificate or other identification document that the account holder provided at account opening has been terminated before its expiration date, or that the account holder has overstayed or been reported missing.
B. Lower Threshold for Bank Action
Under Article 5, Subparagraph 2, Item 1 of the amended Regulations, once a bank concludes through verification and monitoring that a Suspicious Account may involve suspicious or unusual transactions, it may take appropriate measures against the account without first confirming any illegality. Appropriate measures include:
1. notifying a judicial police authority or other law enforcement authorities;
2. suspending all or part of the account’s transaction functions;
3. suspending the account’s ATM card functions, funds transfer by telephone or Internet, and other electronic payment functions; and
4. returning inward remittances to the remitting bank.
II. Impact on Foreign Nationals and Employers, and Our Recommendations
Once a foreign national’s employment in Taiwan ends, the basis for his or her lawful residence may cease to exist, in which case the National Immigration Agency will revoke the residence permit and terminate the Alien Resident Certificate (Article 31, Paragraph 4 of the Immigration Act). As a result, the foreign national’s deposit account may be classified as a Suspicious Account. The bank may suspend transactions, leaving the account holder unable to withdraw deposits or receive remittances and making the remaining balance difficult to handle. In addition, wages, severance pay, and other payments that an employer remits to a foreign worker’s Taiwan bank account after the worker’s departure may be returned under the Regulations and fail to reach the worker on time. This makes it harder for employers to settle all wages as required by law (Article 9 of the Enforcement Rules of the Labor Standards Act), or to issue severance pay on time (Article 17, Paragraph 2 of the Labor Standards Act).
To avoid labor-management disputes arising from restrictions on a foreign employee’s bank account, we recommend that employers of foreign nationals review their offboarding procedures and payment arrangements for departing foreign employees in advance.
