전자금융거래에서 고객(본인)확인에 관한 연구

Financial authorities recently changed the authoritative interpretation that did not allow non-face-to-face identification to verify the customer’s genuine identity. The Real Name Financial Transaction Act requires the verification of the customer’s real name on the banking and it has long been interpreted as face-to-face verification by financial authorities. However, as recognized the establishment of the internet only bank is needed and face-to-face verification obligation is the inconvenient regulation, financial authorities now permit non-face-to-face verification upon account opening under the Real Name Financial Transaction Act. Change of the real name verification method also affects other laws. First of all, Financial Transaction Report Act that is the chief support of our anti-money laundering system will be directly affected. It will be forced to accept non-face-to-face verification of customer’s real name. Although FATF recommendations allow for non-face-to face transactions, the specific risk management measures relating to money laundering has to be added for our circumstances. In terms of Electronic Financial Transaction Act, upon issuing of the access medium, the way of verification of customer’s identity is expected to permit non-face-to-face method. If the authoritative interpretation on Electronic Financial Transaction Act changes like the foregoing, access medium such as OTP can be issued through non-face-to face verification. However, it should be noted that because the purposes of Real Name Financial Transaction Act and Electronic Financial Transaction Act are different, even allowing non-face-to-face verification in the former not necessarily allows non-face-to-face verification in the latter. Lastly, Digital Signature Act that stipulates one must verify the identity of the customer when issuing governmentauthorized certificate does matter. Since face-to-face principle cannot be given up in Digital Signature Act, one cannot help going to the bank for issuing government-authorized certificate even if opening account by non-face-to-face way is allowed. In order to overcome the above problem, it is an alternative to activate a non-government-authorized certificate. With respect to the meaning and the function of verification of customer’s identity, it is necessary to accumulate the theory and practice to meet the respective legislative purposes.