3. Customer information should be reviewed and additionally collected to
support compliance review and analysis of e-wallet accounts and transactions.
Findings:
During the review period, we found that True Money allowed one customer using his/her citizen
ID to register for many True Money e-wallet accounts (mobile numbers) based on the business
concept that one person could possess more than one mobile numbers. And one customer could
apply for more than one e-wallet accounts. .
Additionally, True Money considered and analyzed the occurred transactions including
suspicious transactions based on individual True Money account only (e.g. mobile number), not
based on individual person (citizen ID).
However, from our observation, we noted the following issues:
• There were cases that one citizen ID was used to register/open many e-wallets accounts;
• Some registered citizen IDs were not in formality with the Thai Citizen ID format such as
citizen ID with first digit ‘0’ or ‘9’. Such IDs have no definition according to website of the
Department of Provincial Administration, http://stat.bora.dopa.go.th/fop/pid13.htm);
• And in case of suspicious transactions, if any in the future, True Money may not have
adequate customer information for reporting to the Anti-Money Laundering Office.