According to media reports, some citizens have raised concerns about the Prosecutorial
Office entrusting various branches of the AEA to auction off virtual currencies. They claim
that bidders can directly purchase the currencies with cash without undergoing Know Your
Customer (KYC) procedures, and that the branches have not registered or filed with the
Financial Supervisory Commission (FSC) as required under anti-money laundering laws,
possibly violating regulations.
Article 6 of the Money Laundering Control Act stipulates that any entity or individual
providing virtual asset or third-party payment services must register or file their antimoney

laundering and service capabilities with the competent authority at the central
government level before offering such services. However, under Article 2, Subparagraph 2
of the “Regulations Governing Anti-Money Laundering Registration for Virtual Asset
Service Providers” announced by the FSC, a virtual asset service provider refers to a
business or individual operating within the Republic of China that conducts virtual assetto-currency

exchange activities on behalf of others as a profession. The branches of the
AEA handling the auction and sale of virtual assets at the request of the Prosecutorial
Office do not fall under this definition, and the media reports contain some
misunderstandings.
As the AEA's branches are not virtual asset service providers as defined under Article 6
of the Money Laundering Control Act, they are not required to register or file with the FSC.
This has been confirmed by the Securities and Futures Bureau, and the public’s concern
regarding potential illegality due to lack of registration or filing may stem from a
misunderstanding. Branches entrusted by the Prosecutorial Office to auction seized assets
operate in strict accordance with the Code of Criminal Procedure, the Administrative
Execution Act, and the Compulsory Execution Act, verifying the identity and funds of all
buyers.
For example, in a recent virtual currency auction entrusted to the Taichung Branch,
interested bidders were required to present a National Identification Card or other
identification documents and a letter of authorization to participate in the bidding process.
If a company or business entity participates in the bidding, it must present documents of
incorporation or business registration for identity verification by the branch. After a bidder
wins, the payment is made via wire transfer into an account designated by the Prosecutorial
Office, and the remitting financial institution conducts the KYC process. Cash is not
accepted at the auction site, ensuring that all auctions entrusted to the branches are
conducted lawfully and in compliance.