What to do if a nominee account is accused of fraud or money laundering? A comprehensive guide to warning accounts, subpoenas, and self-protection.

Key Points

When an account is flagged for fraud or money laundering, the organization of evidence directly impacts the direction of the case.

When an account is suspected of being a nominee account, or when you receive a notification of fraud or money laundering under the Anti-Fraud Act, the key is not simply to say that you were also scammed, but to provide objective information that supports your claim of being unaware of the fraud or money laundering, such as job interviews, transaction records, withdrawal records, communication software data, and a timeline of the police report.

• Suitable for people who receive police inquiry notices, district prosecutor's summonses, account alerts, or whose family members are suddenly notified of involvement in fraud or money laundering.
• Key keywords include nominee account lawyers, alert accounts, defendants in fraud and money laundering, money laundering prevention laws, and aiding and abetting fraud.
• If the case involves multiple victims, cross-border money flows, or financial accounts, it is recommended to compile a complete timeline before the first police inquiry.

If your account is being used as a dummy account, the first thing to do is not to rush to explain, but to preserve evidence.

Many people first learn they've become "dummy accounts" not because they've actually joined a fraud ring, but because their bank notifies them that their account has been frozen, salary transfers have failed, they can't open a new account, or they suddenly receive notices from the police station, investigation station, or district attorney's office. Common scenarios include being asked to provide an account to test salary transfers during job interviews, being asked to "beautify" account cash flow when applying for loans, investment platforms requesting to collect payments on their behalf, friends borrowing accounts for short-term loans, or handing over passbooks, debit cards, online banking passwords, or virtual asset accounts without knowing the other party's true identity.

The real danger lies in the fact that the first documents the police and prosecutors see are usually not your complete account, but rather the victim's police report, remittance details, bank reports, and account transaction records. As soon as the victim's funds are deposited into your account, you may be listed as a defendant or suspect in fraud, money laundering, or providing account information cases. Therefore, upon receiving notification, don't just say "I was also scammed," but immediately gather evidence proving how you contacted the other party, why you provided your account information, whether you received payment, whether you knew the source of the funds, whether there were any withdrawals or transfers, when you noticed anything unusual, and when you reported the loss or filed a police report.

What crimes can be committed involving nominee accounts?

There are three most common legal risks in nominee account cases.

I. Ordinary fraud or aiding and abetting fraud. According to...Article 339 of the Criminal LawUsing fraud to induce someone to hand over money can be punishable by up to five years in prison. If a person provides an account but does not directly defraud the victim, but knows or foresees that the account will be used to receive fraudulent funds, they may be considered an accomplice to fraud.

Second, aggravated fraud. According to...Article 339-4 of the Criminal LawIf the fraud involves impersonating government agencies or civil servants, involves three or more people committing the crime together, involves disseminating information to the public through the internet or media, or involves using technological methods to create false images or sounds, the penalty is increased to imprisonment for a term of not less than one year and not more than seven years, and may also be subject to a fine. If the case is found to be related to the division of labor within a fraud syndicate, the risk will be much higher than that of a simple account dispute.

3. Money laundering or aiding money laundering.Articles 2 and 19 of the Money Laundering Control ActMoney laundering includes acts such as concealing proceeds of crime, obstructing investigations into proceeds of crime, and receiving or using specific proceeds of crime from others. The current penalties for money laundering have been increased; if the laundered money or property interests do not reach NT$100 million, the perpetrator can still be sentenced to imprisonment for six months to five years and fined up to NT$50 million.

Could I be penalized just for providing an account?

Yes. CurrentSection 22 of the Money Laundering Control ActIt is explicitly stipulated that no one may hand over or provide their own or another person's financial account, virtual asset account, or third-party payment account to another person for use. However, this restriction does not apply if it conforms to general business and financial transaction practices, or is based on trust between relatives and friends, or other legitimate reasons.

In other words, the law doesn't treat all account borrowing as a crime, but it will examine the reasonableness of the reason. A first offense may result in a police warning; however, if there is payment received, more than three accounts provided, or a repeat offense within five years, it could constitute a criminal offense punishable by up to three years imprisonment, detention, or a fine of up to NT$1 million. More importantly, if the account is subsequently used to receive fraudulent funds, the case usually doesn't stop at Article 22; prosecutors and police will also investigate both fraud and money laundering.

What is the Supreme Court's view on providing accounts versus money laundering?

The Supreme Court's Criminal Division, in its 2019 ruling No. 3101, clarified that simply providing a debit card and PIN to a stranger does not necessarily make one a principal offender in money laundering. However, if the perpetrator subjectively understands that the account may be used to receive or withdraw proceeds of crime, and still provides the account with the intention of aiding and abetting, they may be guilty of aiding and abetting money laundering. This viewpoint is worth referencing.Judicial Yuan Press Release.

In practice, courts won't just look at your verbal statement of ignorance; they will make a comprehensive judgment. Common unfavorable factors include the other party's unknown identity, promises of high rewards, requests for handing over debit cards and PINs, requests to activate online banking, requests for multiple accounts, instructions to delete chat history, requests for in-person withdrawals or transfers, and requests to avoid bank's follow-up questions. If all these situations occur simultaneously, the court is more likely to conclude that you at least had "foreseeable but negligent" actions that were not necessarily intentional.

Conversely, if you can provide complete job application records, loan application materials, the other party's script, fake company or platform information, communication software conversations, loss reporting records, police report records, bank notification times, no receipt of payment, no withdrawals or transfers, etc., you have the opportunity to claim that you are also a victim of fraud, rather than a member or accomplice of the fraud ring.

After the Anti-Fraud Act is amended in 2026, the risk of fraud cases will be higher.

The Act Governing the Prevention of Fraud Crimes was amended on January 21, 2026, and took effect on January 23, 2026. The Taiwan High Prosecutors Office has compiled a list of key amendments, including increased severity levels for high-value fraud, aggravated complex fraud cases, and strengthened provisions for victim compensation and parole thresholds. (For reference...)Taiwan High Prosecutors Office ExplanationandPresidential Office Gazette.

For defendants using nominee accounts, this means the case cannot be understood simply as "I was just borrowing the account." If the account is used in cases involving three or more people committing fraud, fake investments, impersonating police or prosecutors, cross-border data centers, cryptocurrency money laundering, or large-scale financial losses, even if you are not the main suspect, you may be implicated in more serious cases as an accomplice, accessory, or financial intermediary. How you explain your role in the early stages of the investigation will directly influence whether the prosecutor believes you were merely used or were a link in the fraud chain.

What are the consequences of issuing a warning to an account?

Alert accounts are not simply internal bank notes. According to financial regulatory standards, alert accounts are typically designated as alert accounts by courts, prosecutors' offices, or judicial police agencies for use in criminal investigations, requiring the bank to issue an alert.Regulations on the Management of Deposit Accounts and Their Suspected Illegal or Abnormal TransactionsThe warning account may have all transaction functions suspended, and the derivative control account may also have its debit card, online transfer and other electronic payment functions restricted.

The practical impact is direct. Your primary account may be unable to receive payments, make online banking transfers, or use electronic payments normally, and other bank accounts may also be subject to derivative restrictions. When applying for a new account, banks may refuse to open an account due to warning records; even for salary transfer accounts, you may need to provide proof of employment or documents from your employer. This will affect your work, loans, credit cards, and daily payments.

What should you do after receiving a summons from the police or the district prosecutor's office?

First, confirm whether the person on the summons is a defendant, suspect, witness, or related party. Different identities have different rights and obligations. If listed as a defendant or suspect, the content of their statement may directly affect whether or not prosecution is initiated.

Second, organize the timeline. From the first contact with the other party, their request for your account, your delivery of documents, unusual transactions in the account, bank notification, reporting the loss, filing a police report, and receiving the summons, every point in time should be documented with screenshots, text messages, emails, call records, platform pages, and remittance details.

Third, do not delete conversation history. Many people are afraid of being seen by family or company, so they delete messages on LINE, Telegram, WhatsApp, or job search platforms first. This makes it harder to prove "I was also scammed." Even if the content is incomplete, you should back up your phone, take screenshots, export the conversation, or keep the record in the cloud.

Fourth, do not fabricate a consistent account of events. Inconsistency is the worst thing that can happen during an investigation. If you genuinely cannot remember something, you should honestly explain that you need to look it up and fill in the gaps, rather than guessing dates, amounts, or the other party's name to make the story seem complete.

Fifth, assess as early as possible whether a lawyer is needed to accompany the suspect during questioning. Cases involving nominee accounts often involve criminal law, money laundering control laws, removal of alerted accounts, and victim settlements. Fidelity Law Firm can assist in reviewing financial records, communication records, and subpoena content to determine whether to assert lack of criminal intent, being fraudulently exploited, or having a low degree of accompliceship, or to pursue settlement, compensation, or deferred prosecution.

Under what circumstances is there a better chance of getting a no-prosecution or acquittal?

Whether you can get a no-prosecution, acquittal, or a lighter sentence usually depends not on whether you plead innocent, but on whether your evidence can convince the prosecutor or the court.

First, is your reason for providing your account reasonable? For example, is it for legitimate job seeking, loan applications, platform transactions, or trust between relatives and friends? Are there any relevant advertisements, contracts, conversations, application materials, or identity verification records?

Second, did you receive any compensation? If you received money, a cut, a daily wage, or a commission, the police and prosecutors will usually assume that you knew the account was not for ordinary purposes. If you did not receive any benefits and can explain why you trusted the other party, it will be more advantageous for your defense.

Third, have you relinquished full control? Providing only an account number for remittances carries different risks than handing over your debit card, password, online banking password, and mobile OTP verification. The more complete the delivery, the more you need to explain why it's reasonable.

4. Did you participate in withdrawals or transfers? If you personally withdraw money at a counter, withdraw it from an ATM, purchase cryptocurrency, or transfer it to someone else's account, the case is usually more serious than if it were just an account transaction.

5. Did you take immediate action after discovering the anomaly? Reporting the loss, filing a police report, notifying the bank, calling 165, and keeping the three-part receipt and notification record are all important documents for determining whether you genuinely intended to prevent the damage from escalating.

Is it necessary to reach a settlement with the victim?

Settlement is not necessary in every case, nor is it better to pay as early as possible. If the facts of the case, the flow of funds, and the proportion of liability have not been clarified, rushing to sign documents that "admit fraud" or "agree to assume full liability for compensation" may become detrimental evidence in criminal proceedings.

However, in some cases, if the prosecutor has a clear understanding of the financial flow and your role is difficult to completely sever, appropriately mediating with the victim, offering compensation, or proposing installment plans may help in securing deferred prosecution, a lighter sentence, or reducing the risk of civil claims. The key is to ensure the settlement terms are precise; avoid writing "moral assistance" as "admission of guilt," and also avoid assuming amounts exceeding your legal liability.

How does Fidelity Law Firm assist with nominee accounts and fraud/money laundering cases?

When handling cases involving nominee accounts, fraud, money laundering, and alerted accounts, Fidelity Law Firm starts with the flow of funds and evidence, rather than relying solely on abstract arguments. We assist clients in compiling account transaction records, communication records, job application or loan documents, bank notices, police reports, and summons contents to determine whether the case should be pursued in the direction of no intent, victim status, accomplice, reduced sentence, settlement, or lifting of account restrictions.

If you have received a notification from the police station, investigation station, or district prosecutor's office, it is recommended that you consult a lawyer before giving your first statement. The first statement is often the foundation of the entire case. The sooner the facts and legal position are clarified, the better you can avoid portraying a simple case of being taken advantage of as an irreparable criminal division of labor.

VI. FAQs in the main text

Frequently Asked Questions

Will a dummy account always be shut down if it's accused of fraud?

Not necessarily. The court will consider whether you knew the account might be used to receive fraudulent funds, whether you received payment, whether you provided multiple accounts, whether you cooperated with withdrawals or transfers, and whether you immediately reported the loss, filed a police report, and preserved evidence afterward. If you can prove that you were tricked into providing your account under job, loan, or investment fraud, there is still room to fight for non-prosecution, acquittal, or a lighter sentence.

Can I remove the warning from my account myself at the bank?

Normally, one cannot simply go to the bank to request the removal of a warning account. Warning accounts are created by courts, prosecutors' offices, or judicial police agencies in connection with criminal investigations. Banks usually require the original notifying agency to lift the notification or warning period before the restriction can be lifted. In practice, one should first confirm the notifying agency, case number, and the victim's financial flow, and then assess whether to submit reasons and supporting documentation to the handling agency for removal or partial removal.

Should I try to reach a settlement with the victim before receiving a police summons?

It is not advisable to hastily admit liability or make payments before fully understanding the facts of the case. While a settlement may help reduce sentencing or secure deferred prosecution, if the payment clause admits to fraud or assumes full liability, it could have adverse criminal and civil consequences. The flow of funds, roles, evidence, and scope of liability should be confirmed before deciding whether to settle and how to draft the settlement terms.

If someone is scammed out of their account while job hunting, can that constitute money laundering?

There is still a possibility of investigation, but it doesn't necessarily mean a crime has been committed. The key is whether you can prove the job application process, the other party's script, company or platform information, communication records, that you did not receive any payment, did not withdraw or transfer any money, and that you immediately reported the loss or filed a police report after discovering the abnormality. This information can be used to argue that you lacked the intent to defraud or launder money.

Do I need a lawyer in a case involving nominee accounts?

If you have received a summons identifying you as a defendant or suspect, it is advisable to consult a lawyer at least before your first statement. Cases involving nominee accounts often involve fraud, money laundering, providing accounts, warnings of account closure, and victim claims. If the timeline and evidence are not properly organized in the initial statement, subsequent revisions will be much more difficult.