Opinion: The Biggest Loophole in Anti-Fraud Efforts — 'Trustworthy People' — Can Lawyers Become a Credibility Endorsement?

When discussing anti-fraud efforts in Taiwan, what is the most familiar scene? Bank tellers earnestly trying to stop money transfers, police rushing to ATMs to stop elderly people from withdrawing cash, or young cash couriers being arrested on the streets carrying bundles of cash. Thus, when the government announces its anti-scam achievements, we are accustomed to seeing figures on how many billions of dollars were blocked, how many couriers were arrested, and how many dummy accounts were seized.

However, a recent indictment by the Taichung District Prosecutors Office involving a vaccine procurement case has revealed a more alarming issue in anti-fraud governance: What if the person on the other side of the transaction isn’t an anonymous internet stranger, but someone with professional qualifications, social standing, and even former leadership roles in professional associations? Will our anti-fraud alarms still go off?

According to prosecutors, Chen Yu-hsuan, former chairman of the Changhua Bar Association, and 16 others are suspected of claiming access to BNT vaccine supplies during the 2021 pandemic, leading Tzu Chi to pay a commission of USD 30 million (approximately NT$1.06 billion). Prosecutors further allege that these funds were subsequently laundered through shell companies, cash withdrawals, and gold purchases. Of course, whether the defendants are ultimately found guilty remains subject to judicial review.

The real concern is that the criminal structure outlined by prosecutors alone should prompt a fundamental reevaluation of Taiwan’s anti-fraud policies.

This is not a typical 'guess who I am' scam, but a more sophisticated 'believe who I say I am' scheme.

The true sophistication of the fraud industry lies not in lying, but in lowering victims’ suspicion costs. Fake police officers wear uniforms, investment scams build fake websites, romance scams craft elaborate personas—all fundamentally designed to manufacture 'credibility.' Professional credentials such as lawyers, accountants, land surveyors, and financial advisors are institutional mechanisms meant to reduce transaction risks in modern society. When these credentials are instead weaponized as credibility endorsements for criminal transactions, the resulting danger far exceeds that posed by street-level couriers.

This also highlights a long-standing paradox in Taiwan’s anti-fraud policy: massive law enforcement resources are spent chasing the least powerful individuals, while insufficient systems exist to monitor those most capable of executing complex transactions.

A 19-year-old courier withdrawing NT$200,000 might trigger an immediate bank alert. But when professionals with established backgrounds are involved in billion-dollar transactions, complete with documents, corporate entities, contracts, and formal mandates, the activity easily assumes the appearance of 'legitimate business.'

As a result, police may catch the person withdrawing cash, financial institutions may track the transfer, and prosecutors may eventually trace the recipient—but the real challenge is whether the system can detect something wrong with the transaction before NT$1 billion leaves the country.

This is the next battlefield for anti-fraud efforts.

First, anti-money laundering systems must move beyond tracking 'which account the money came from' to asking 'who is providing credibility for this transaction?' When professionals are involved in abnormally large transactions, overseas payments, complex corporate structures, or high-risk asset conversions, regulators and industries must establish more mature risk identification mechanisms.

Second, the conversion of large amounts of cash, gold, and other highly liquid assets must become key nodes in financial intelligence analysis. Criminal groups continuously change their money laundering tools precisely because bank account monitoring has become increasingly strict. If regulatory thinking remains fixated on bank transfers, criminal funds will naturally seek the path of least resistance.

More importantly, major religious, charitable, and non-profit organizations conducting significant cross-border procurements or委托 transactions should implement third-party due diligence standards comparable to those used in corporate investments. A professional’s business card cannot serve as a performance guarantee; a professional association title cannot replace verification of funding capacity, supply sources, ultimate beneficiaries, or counterparty checks. The larger the amount, the higher the degree of cross-border involvement, and the more unique the transaction object, the greater the need for cross-verification, performance guarantees, and phased payments.

Taiwan has invested substantial resources in anti-fraud efforts in recent years, and police forces bear heavy caseloads and performance pressures. However, if policy continues to center on metrics like 'how many couriers were caught' or 'how many transfers were blocked,' a paradoxical situation arises: frontline officers chase 20-year-old couriers outside convenience stores, while truly complex billion-dollar transactions quietly conclude in conference rooms, dressed in suits and armed with contracts.

Couriers must be apprehended, but they are merely the cheapest and most replaceable consumables in the crime supply chain.

Truly mature anti-fraud governance must evolve from 'identifying suspicious individuals' to 'identifying abused trust.' Bank accounts can be exploited, corporate entities can be exploited, and professional credentials can likewise be exploited. The most basic principle of criminal economics is that offenders seek the lowest-cost, highest-success pathways through institutional gaps. When governments block dummy accounts, criminals simply find new credibility carriers.

Therefore, regardless of the court’s final ruling in this case, it raises a deeper policy question: Has Taiwan’s anti-fraud system become too accustomed to guarding against people who 'look like criminals,' while failing to adequately guard against those who 'appear most trustworthy'?

The most dangerous aspect of fraud has never been lies from strangers, but trust provided by familiar systems.

When a lawyer’s business card, a professional title, or a formal contract can lower people’s guard, anti-fraud policy can no longer remain stuck in public messaging urging people 'not to trust strangers.'

Because the next generation of hardest-to-detect scams may well come precisely from—the people we have the strongest reasons to believe.

*Author is an adjunct professor at a university