Concerning online applications for trust accounts opening by customers with an existing deposit account, the Bank failed to set up operating procedures for ongoing customer due diligence to assess customers’ risk. The Bank, which had deficiencies in failing to establish an internal control system properly, and therefore, detrimental to identifying, assessing and monitoring money laundering risk, violated Paragraph 1 of Article 45-1 of the Banking Act. The FSC thus imposed a fine of NT$2 million under Subparagraph 7 of Article 129 of the Banking Act at the time of the conduct occurred.