Korean Financial Watchdog Takes Action to Prevent Abnormal Foreign Currency Transfers
According to yesterday’s press release, the South Korean Financial Supervisory Service (FSS) has undertaken measures to tackle the issue of abnormal foreign currency transactions disguised as cross-border trade transactions. After identifying suspicious transactions of a total of approximately $7.2 billion involving 83 companies, the FSS has collaborated with the Korea Federation of Banks and domestic financial institutions to establish a task force. The objective is to improve the existing system and prevent such occurrences in the future.

Weaknesses in internal controls
During inspections conducted within the banking industry since June 2022, the FSS uncovered weaknesses in internal controls related to foreign currency transfers. These included instances where banks neglected to verify the required documents for transfers and failed to detect abnormal transactions that had been ongoing for an extended period of time. The abnormal foreign currency transfers primarily involved funds flowing out of Korean virtual asset exchanges and being sent overseas under the pretense of trade transactions.
Three-line defense internal control system
To address these vulnerabilities, the task force has engaged in discussions and decided to build an internal control framework within the banking industry, rather than to add a new procedure. This was to minimize the disruption that the new system can pose to banks regarding foreign exchange transactions. The dedicated group has introduced a three-line defense internal control system.
The new internal control system comprises three parts. Firstly, it involves standardizing a checklist of vital checkboxes that must be completed before initiating advance remittance transfers for imports. Secondly, the monitoring system employed by banks will be strengthened. Lastly, a follow-up system will be developed, clearly outlining the roles and responsibilities of banks and incorporating a review process.
Implementation and timeline
Banks plan to implement these improvement measures in July, following necessary preparations such as guidelines revision and rules update in the second quarter of this year. Since developing a computerized system and devising new procedures may require additional time, they will be gradually introduced in the third quarter.
The FSS expects these improvements will ensure the systematic operation of banking institutions’ internal control functions related to cross-border prepayments, thereby preventing suspicious foreign currency transfers and curtailing companies’ risks of violating their obligations.


