TAIWAN Trends and Developments Contributed by: Robin Chang, Sarah Wu and Eddie Hsiung, Lee & Li
E-Payment: Cross-Border Payment/Remittance Services Under Taiwan’s Electronic Payment Institutions Act (“E-Payment Act”), which regulates the e-payment sector, Taiwan e-payment service providers are per - mitted to co-operate with foreign e-payment service providers to offer certain types of cross-border pay - ment services in Taiwan, subject to the approval of the FSC. In 2021, the E-Payment Act and related FSC reg - ulations underwent an amendment. This amendment simplified the required documents and the application process for cross-border co-operation. Additionally, it expanded the range of cross-border payment/remit - tance services that can be provided. As a result, it is anticipated that there will be an increase in the number of cross-border payment/remittance services offered in Taiwan under the revised E-Payment Act. AML With more and more criminal frauds involving emerg - ing payment methods, anti-money laundering (AML) has become a widely discussed topic in the Taiwan regulatory environment in recent years. According to the Money Laundering Control Act as amended in 2024 (“Taiwan AML Act”), the Regulations Governing Anti-Money Laundering and Countering the Financ - ing of Terrorism for Enterprises Providing Third-Party Payment Services, and the Regulations Governing the Capacity Registration for Anti-Money Laundering and Countering the Financing of Terrorism for Enterprises Providing Third-Party Payment Services, “third-party payment service providers” are required to register with the Ministry of Digital Affairs for AML purposes, as well as complying with other obligations as required by these regulations. Under the Taiwan AML Act, the Regulations Govern - ing the Anti-Money Laundering Registration for VASPs (“Crypto AML Registration Regulations”), and the Regulations Governing Anti-Money Laundering and Countering the Financing of Terrorism for Enterprises Providing Virtual Asset Services, virtual asset service providers (VASPs) must register with the FSC for AML purposes based on the types of services they render. Given that criminal liability applies for failing to com - plete the AML registration as outlined above, industry players are generally expected to incur higher compli -
ance costs and efforts as a result of both regulatory moves mentioned above. Cryptocurrency STOs Since the introduction of the regulations governing security token offerings (STOs) in 2020, there had been no STO programmes issued under these regulations until the announcement of the first STO programme in 2023. Relevant news reports indicate that the STO in question is a bond-type offering. It is therefore worth monitoring whether any other STO programmes will be launched in the near future. It is generally consid - ered that the limited number of STO programmes can be attributed to various factors, including limitations such as the maximum issuance amount allowed for a single STO programme (TWD30 million), the maximum investor amount for individual investors (TWD300,000 for natural person professional investors), and the costs associated with launching an STO, such as intermediary fees. Specific crypto law? The FSC is exploring the introduction of a specific law to enhance the regulation of VASPs, with a draft released by the FSC in June 2025. According to relevant news reports, it is generally expected that the new legislation may transition from the current “registration” system under the AML framework to a “licensing” model, requiring VASPs to obtain a licence from the FSC before offering virtual asset services. Key areas of focus for the new law are expected to include minimum capital requirements, qualifications for executives, and customer protection. Stablecoin Nowadays, when discussing the policy aspects of cryptocurrency, stablecoin is a topic of heavy debate. Many argue that stablecoin should be treated differ - ently from other cryptocurrencies. Nevertheless, the application of current laws and regulations should depend on the specific charac - teristics, framework and models associated with the stablecoins. Consequently, the issuance and use of stablecoins might fall under the jurisdiction of various laws and regulations, such as those governing pay - ments or potentially even securities.
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