전자금융거래에서의 기망승인(APP) 사기 피해자 보호체계 비교 – 한국·미국·영국의 법제와 정책을 중심으로–

In the United States, the Electronic Fund Transfer Act (EFTA) and related regulations protect consumers in the event of an unauthorized transaction. However, the recent surge in Authorized Push Payment (APP) fraud, which tricks consumers into authorizing direct wire transfers, has exposed the limitations of the existing legislation. While there are relatively strong refund and remedy systems in place for unauthorized transactions, there is not enough protection for victims of APP fraud, where the user voluntarily authorizes the transfer. This is in contrast to new legislative attempts to protect victims of APP fraud in some countries, such as the United Kingdom, which has a mandatory refund system. In the U.S., the need for legal and institutional improvements for APP fraud victims has been consistently raised, and related bills have been introduced, but specific legislative discussions are still in the early stages due to opposition from the banking industry and political dynamics. The purpose of this study is to systematically analyze the main contents of the U.S. and U.K. remittance and payment service consumer protection laws and policies in terms of fraud protection systems, and to identify the limitations of the Korean system and directions for improvement. To do so, we adopted the methodology of reviewing the major laws, policy trends, and supervisory cases in the United States and comparing and analyzing them with the current system in Korea.