金融自由化於一九六○年代末期發端於德、英二國後，隨即迅速傳佈至世界各地，蔚成一種國際化潮流趨勢，在全球金融一片國際化、自由化的風潮下，各國金融機構將來必定面臨外來金融機構競爭之挑戰，我國未來金融的發展，可預見在金融自由化的浪潮下，為配合市場自由化發展趨勢，其配套相關之法律和制度應重新規範，促進我國金融機構競爭力的提升及維持良好金融秩序。 本篇論文探討金融機構綜合經營金融業務下之優缺點，針對金融機構綜合經營後之弊端如何設立防火牆來減少其負面影響，藉由探討美、日目前金融綜合經營下，相關之法律及制度上之設計，以作為未來我國走向金融機構綜合經營下，相關金融法規（包括銀行法、證券交易法、保險法、金融合併法等等）之修正及訂立完整的法律規範之參考。 / Insurance activities bear important similarities to banking. Insurance companies collect premium payments as banks collect deposits; insurance companies intermediate funds received into loans and investments as do banks; insurance companies eventually repay their policyholders as banks repay their depositors; and insurance companies sell their products through local office networks as do banks. Because of these similarities, there is a strong trend that permitting affiliations between banking and insurance companies for the institutions, as well as significant benefit to consumers in the form of greater convenience and potentially lower costs. After a decades-long effort, historic financial modernization legislation was signed into law by the President of United States on November 12, 1999. The Gramm-Leach-Bliley Act will eliminate the artificial depression-era barriers between companies that sell securities, insurance, and banking products. The act involves authority governing consumer protection and information sharing. In 1992, Japan approved the “Financial Systems Reform Act”, amending Japan’s Securities Law, Banking Law, Insurance Law etc..The Ministry of Finance has elected to restrict the range of powers permissible for new subsidiaries of banks, securities, insurance. We move forward, domestic financial deregulation in eliminating barriers between companies that sell securities, insurance, and banking products. We need to give attention to the potential risks. Through making financial act providing a comprehensive framework, we maintain the safety and soundness of our financial institutions.