FSC Taiwan Fines Sanyuan Construction Responsible Person NT$240,000 and Accountant NT$250,000 for AML Violations

The FSC Taiwan issued two enforcement actions on April 17, 2026. The first case involved Sanyuan Construction, where a responsible person was found to have extended short-term financing to third parties with loan periods exceeding 1 year without recovery, in violation of Article 3 of the Public Issuance Company Fund Lending and Endorsement Guarantee Processing Guidelines, resulting in a NT$240,000 fine under Securities Transaction Act Article 178(1)(11) and Article 179. The second case involved accountant Zheng, who was found during an on-site AML/CFT audit by the FSC Taiwan委托中華民國會計師公會全國聯合會 on November 17, 2025 to have multiple deficiencies in client due diligence including failure to obtain articles of incorporation, MOEA commercial registration, and beneficial ownership identification; failure to assess customer risk profiles; failure to verify PEP status via external databases; failure to screen against Ministry of Justice sanctions list; and failure to evaluate whether suspected money laundering transactions required reporting to the MJ Investigation Bureau. The accountant was fined NT$250,000 under Money Laundering Prevention Act Articles 8(5) and 13(5). Accountants and public companies subject to FSC Taiwan oversight should review their AML compliance procedures against the specific deficiencies identified in the Zheng case.