중앙은행 디지털화폐(CBDC)와 금융거래정보 보호

Central Bank Digital Currency (hereinafter referred to as 'CBDC') is a digital currency issued by the central bank. The issuance and transaction records of CBDC are implemented in CBDC ledgers or electronic devices. It is necessary to protect personal information that can be collected and used in the process of operating the CBDC system. On the other hand, it is necessary to comply with Anti-Money Laundering regulations. In this respect, CBDC cannot be designed to maintain the same level of complete anonymity as cash. Determining the appropriate level of anonymity or personal information protection of the CBDC system is a matter of technology design that sentences various legal principles such as Anti-Money Laundering. Each intermediary institution can acquire personal information when opening a CBDC electronic wallet, and when accessing the electronic wallet after opening. Next, CBDC transaction records such as electronic wallet address, transaction amount, and usage time recorded in the ledger during CBDC transactions can be hash encrypted based on distributed ledger technology and privacy-enhancing technologies. However, in exceptional cases such as financial supervision or law enforcement, it can be designed to identify individuals through decryption procedures. Therefore, CBDC transaction information is not anonymous information under the Personal Information Protection Act, but pseudonym information, in that the possibility of identifying individuals through additional information is open. Information obtained before CBDC issuance and when accessing the CBDC system needs to be stored separately by individual intermediaries on a distinct server from the CBDC transaction ledger. Furthermore, transaction information recorded in the ledger during CBDC transactions should be minimized and pseudonymized as essential information for transactions. This is because it is difficult to change or delete information recorded in the ledger when using distributed ledger technology, and information is continuously accumulated. Transaction transparency should not be guaranteed enough for state agencies to know transaction details without any separate measures. It is necessary to design it to receive transaction information from CBDC ledger nodes for financial supervision or law enforcement. In addition, it is desirable to guarantee the right to choose a payment method by continuing to issue cash and to guarantee the right to use or move CBDC users' transaction records.