**News Insights**
Global governance is shifting from simple compliance management to refined risk management. According to the Financial Supervisory Commission's "Elderly Economic Security Protection Program (2021-2025)," as Taiwan enters an aging society, the rise in dementia cases has created severe financial security challenges. The FSC has explicitly incorporated dementia awareness, property trusts, and insurance issues into the financial system and strengthened oversight of sales of investment-linked insurance products to elderly clients to prevent financial exploitation. Meanwhile, government governance is pursuing systemization. In November 2026, the Ministry of Justice's Anti-Corruption Agency released the list of outstanding agencies for the fourth "Transparency Crystal Award," demonstrating how the principles of ISO 37001 anti-bribery management systems are integrated into administrative processes. For example, the National Police Agency under the Ministry of the Interior adopted blockchain technology to establish a "Digital Evidence Chain," and the Kaohsiung City Tax Administration Office used RPA to automate processes and reduce human error, reflecting the trend of converting anti-corruption mechanisms into management systems. Additionally, cross-border supply chain management has new regulations. In 2026, Vietnam's Ministry of Industry and Trade issued Circular No. 31/2026/TT-BCT, requiring companies to establish product and commodity traceability mechanisms to strengthen market management and consumer protection. This shows that from finance, government agencies to international trade, governance priorities are shifting from "moral self-discipline" to "systematic risk control."
**Winners Insights**
We observe that for corporate C-suite executives, this governance wave means risk management must shift from "reactive remediation" to "proactive systemization." We focus this issue on the roles of "Chief Risk Officer (CRO)" and "Legal Officer" because these positions must handle increasingly refined regulatory boundaries. Non-compliance may lead to more than just penalties—it can result in severe reputational damage and market access barriers. For example, if financial institutions fail to implement the FSC's "Know Your Customer" policies or "Customer-Friendly Service Standards," they may face heightened penalties for deficiencies in selling products to elderly clients. We infer that current corporate risk management challenges are transitioning from "isolated failures" to "systemic deficiencies" assessments (based on: ISO 31000 risk-based approach; factual material: FSC includes financial exploitation cases in inspections → framework requirement: risk identification and assessment → conclusion: risk management must cover customer lifecycle management).
When implementing such systematic management, companies often have two blind spots. First, they mistake "compliance" for "document completeness." Many companies merely display ISO certifications or ESG statements on their walls without integrating risk control points into daily operational workflows (e.g., integrating anti-fraud, anti-bribery, and traceability mechanisms with ERP or CRM systems). Second, they overlook "cross-departmental responsibility boundaries." For example, financial risks are classified solely as compliance department issues rather than shared responsibilities for product development or sales teams. We infer that if companies fail to establish a cross-departmental responsibility matrix, risk management will fail to reach core business operations (based on: RACI responsibility matrix; factual material: FSC requires headquarters to educate branches → framework requirement: responsibility allocation → conclusion: management responsibility must extend vertically downward). Such risks, if occurring in cross-border supply chains, such as non-compliance with Vietnam's latest traceability circular, may lead to product seizures or inability to sell in the local market, resulting in commercial impacts.
**Action Recommendations**
To avoid becoming victims of regulatory failures or supply chain risks, we recommend the following actions:
1. **Establish a Risk Point Correspondence Matrix**: Break down the latest regulatory requirements (e.g., dementia-friendly finance, product traceability circulars) into specific operational workflows. For example, convert "traceability" requirements into mandatory documents in the "supplier management process." This is a foundational "first step" with the highest priority.
2. **Embed Risk Management into Existing Systems**: Avoid creating a separate system. Incorporate new risk points (e.g., elderly customer risks) into existing "Know Your Customer (KYC)" or "internal control self-assessment" processes to reduce redundant manpower investment. This helps transition risk management from "project-based" to "standardized."
3. **Enhance Digital Audit Capabilities**: Follow government examples by adopting RPA or AI-assisted tools for data comparison and anomaly detection. This not only reduces human error but also provides verifiable audit records that meet ISO 37001 and other management system requirements.
4. **Establish a Cross-Departmental Responsibility Matrix (RACI)**: Clearly define each department's role in risk management. For example, sales teams are responsible for "execution," compliance teams for "consultation and supervision," and audit teams for "independent verification." This prevents responsibility shifting and ensures traceable risk management.
5. **Conduct Regular Gap Analyses**: Periodically review existing processes against new regulatory or market requirements to identify gaps. This helps management prioritize investment and optimization efforts.
We recommend that companies incorporate the above actions into their overall Enterprise Risk Management (ERM) governance framework. By adopting ISO 31000 risk management standards or integrating COSO frameworks, companies can transform risk management from a "cost center" into a "competitive advantage." If you need precise risk assessments, our company offers professional risk management diagnostic services to help establish internationally compliant resilient management systems.
FAQ
- 金融機構如何應對金管會對高齡客戶的監理要求?
- 金融機構應將失智風險納入「認識客戶政策」與「風險管理流程」。根據金管會推動之計畫,機構須強化對高齡客戶銷售投資型保險商品的控管,並建立友善服務措施。建議將風險點納入年度內控自評,並針對高齡交易異常建立持續監控機制,以符合監理檢查中對金融剝削案件的審查標準。
- 產品溯源機制對跨國貿易企業有什麼實質意義?
- 根據越南商工部第 31/2026/TT-BCT 號通達,建立溯源機制不僅是為了符合當地市場管理,更是為了強化供應鏈透明度。企業應將溯源數據整合至品質管理系統,確保產品從原材料到流通過程皆有紀錄。這不僅能快速應對產品回收或品質爭議,更能作為企業在國際市場建立信任與競爭力的基礎。
- 如何將系統化管理與企業既有制度進行有效融合?
- 企業應避免另建平行制度,而是將新風險點併入既有流程。例如,將「防賄賂」或「產品溯源」的要求,轉化為現有「供應商管理」或「內控審核」中的檢查項目。透過建立 RACI 責任矩陣,明確劃分各部門在風險管理中的角色,並將風險指標納入年度管理報告,即可達成低成本、高效率的合規管理。
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- How to choose an ISO 37001 consultant in Taiwan: ten criteriaWhen choosing an ISO 37001 consultant, first confirm the work follows the 2025 edition and that a 2016 certificate can be transitioned by 28 February 2027; then check that the bribery risk assessment covers agents, overseas markets and cross-border bribery under Article 11 of the Anti-Corruption Act, and that the consultant is honest that certification is not a legal defence.
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