Univerisity of Qom Comparative Studies on Islamic and Western Law 2476-4213 12 2 2025 06 22 Comparative Study of Approaches to Protecting Citizens' Financial Privacy (from the Perspective of Economic Analysis of Law) Comparative Study of Approaches to Protecting Citizens' Financial Privacy (from the Perspective of Economic Analysis of Law) 141 176 2968 10.22091/csiw.2024.9774.2445 FA Marziyeh Zookinejad Department of Law, Neyshabur Branch, Islamic Azad University, Neyshabur, Iran. Journal Article 2023 08 24 Today personal privacy preservation in information exchange is essential for any transaction across all markets, especially in financial markets. Financial privacy is defined as the claim of individuals, groups, or institutions to determine the time, quality, and the extent of personal financial information sharing with others. In this research, financial privacy protection approaches including self- regulation, technological and legal approaches were investigated from the perspective of economic analysis of rights by using descriptive-analytical method. The comparative analysis showed that if the goal is<br />to protect the right to financial privacy, definitely self-regulation and technological approaches will not work to protect financial privacy; but if the goal is to increase the total welfare through the balance of business needs to share financial data and the desire of individuals to protect it, there are several reasons that can tip the balance toward a legal approach that provides greater privacy protection, including the sensitivity of financial data and society's expectation of precise legal protections, as well as the greater efficiency of legislation where individuals in society bargain to achieve adequate preserving of their financial privacy. Despite having the utilitarian approach in the field of privacy, the law of the United States of America has established several independent laws in the field of privacy to achieve this balance. There is no specific law dedicated to the issue of financial information privacy in Iranian law; but there are laws from which the principle of protecting financial privacy can be deduced. Therefore, the financial privacy protection rule and the exceptions to it should be under a lawful system. Today personal privacy preservation in information exchange is essential for any transaction across all markets, especially in financial markets. Financial privacy is defined as the claim of individuals, groups, or institutions to determine the time, quality, and the extent of personal financial information sharing with others. In this research, financial privacy protection approaches including self- regulation, technological and legal approaches were investigated from the perspective of economic analysis of rights by using descriptive-analytical method. The comparative analysis showed that if the goal is<br />to protect the right to financial privacy, definitely self-regulation and technological approaches will not work to protect financial privacy; but if the goal is to increase the total welfare through the balance of business needs to share financial data and the desire of individuals to protect it, there are several reasons that can tip the balance toward a legal approach that provides greater privacy protection, including the sensitivity of financial data and society's expectation of precise legal protections, as well as the greater efficiency of legislation where individuals in society bargain to achieve adequate preserving of their financial privacy. Despite having the utilitarian approach in the field of privacy, the law of the United States of America has established several independent laws in the field of privacy to achieve this balance. There is no specific law dedicated to the issue of financial information privacy in Iranian law; but there are laws from which the principle of protecting financial privacy can be deduced. Therefore, the financial privacy protection rule and the exceptions to it should be under a lawful system. https://csiw.qom.ac.ir/article_2968_d21e9db1bf17b018aa724d62b811e522.pdf