- The revision to the Foreign Exchange Transactions Act creates a registration requirement for virtual-asset transfer businesses and introduces penalties including up to three years in prison for operating without registration, increasing regulatory risk.
- Rules covering transactions with a substantially similar effect — potentially including stablecoins and DEX trades — could vary widely in scope depending on the presidential decree.
- Criminal penalties tied to unauthorized currency swaps and kimchi premium arbitrage, along with the standard for unjust gains and the distinction between “transfer” and “payment,” remain unclear, making the enforcement decree especially important.
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