On 20 August 2026, an amendment to Korea's Act on Reporting and Using Specified Financial Transaction Information — the statute behind the country's virtual-asset service provider (VASP) filing regime — comes into force. The filing requirement itself is not new. Operating a virtual-asset business aimed at the Korean market has required a filing with the Korea Financial Intelligence Unit since March 2021, and the Act expressly reaches conduct outside Korea whose effects land inside it. What changes on August 20 is the gate. The amendment, promulgated on 19 February 2026, adds a set of new grounds on which the FIU can refuse to accept a filing — and several of them are aimed squarely at facts that live outside Korea.

What the amendment adds

  • Foreign records become disqualifying. The list of disqualifying convictions is expanded — narcotics-trafficking, fair-trade, tax-crime, aggravated-economic-crime, and virtual-asset user-protection laws join it — and the statute now expressly counts convictions under "equivalent foreign laws," together with prison sentences under other foreign laws covering financial or money-laundering crime, within a five-year window.
  • Major shareholders enter the review. A new statutory definition captures the largest shareholder and any holder of ten percent or more of voting shares, along with anyone exercising de facto control over management. Disqualification grounds that previously reached the representative and officers now reach major shareholders as well.
  • Financial soundness and social credit. A filer — including its representative, officers, and major shareholders — that does not meet standards of sound financial condition or social credit, to be set by decree, can be refused on that basis.
  • Compliance readiness itself. A filer without the organization, personnel, IT systems, and internal-control framework adequate to comply with the Act and Korea's other virtual-asset laws can be refused on that ground alone.
  • Paperwork quality, and a catch-all. False statements or omissions in the application are now an express refusal ground, and a final catch-all delegates further grounds to decree.
  • Conditional acceptance. The FIU may attach conditions when it accepts a filing or a change filing — a new instrument that did not exist under the old text.

The foreign-record clause deserves the closest read

For a foreign operator, the striking change is the first one. Under the old text, the disqualification list was drawn from Korean statutes. Under the new text, a conviction under a comparable foreign law counts, and so does a prison sentence under any foreign law regulating financial or money-laundering crime. A regulatory chapter that was closed at home — a plea, a settlement with an admission, a conviction of a subsidiary's officer — can become a live filing issue in Korea, and because the grounds now extend to major shareholders, it can surface through the ownership structure rather than the operating entity. The financial regulator has said publicly that once the amended Act is in force, involvement in unlawful unregistered operation can bar a party from becoming a major shareholder of a Korean VASP for a period — extending what was previously a management-level restriction to capital participation itself.

Compliance readiness is now a filing ground, not a supervision topic

The internal-controls ground changes the sequencing of a Korean market entry. Under the old regime, organization and controls were largely matters the regulator examined after a filing was accepted. Under the new text, they are examined at the gate: a filer that has not built the compliance apparatus — people, systems, controls — appropriate to the obligations it is taking on can be refused for that reason alone. Combined with the new power to accept filings subject to conditions, the practical effect is that the state of your compliance program on the day you file, not the day you are inspected, is what the gate measures. Filings also run on a three-year cycle, and on the face of the statute the expanded grounds apply to filings accepted after the effective date — which, as renewal dates come around, brings incumbents to the same gate.

August 20 is the first of two dates

A second regime follows within months. On 3 December 2026, amendments to the Foreign Exchange Transactions Act take effect, creating a registration requirement for the business of cross-border virtual-asset transfer — moving virtual assets across the Korean border by way of sale, purchase, exchange, transfer, custody, or management — administered by the Ministry of Finance and Economy. Brokerage and intermediation of such transfers will require a license rather than a registration, and unregistered operation carries up to three years' imprisonment or a fine of up to KRW 300 million. Registration presupposes a completed VASP filing, so the two regimes connect in series: an operator that cannot clear the August gate cannot reach the December one.

That also completes a familiar Korean pattern. The VASP filing sits with the FIU, the user-protection regime sits with the Financial Services Commission, and the cross-border registration will sit with a third authority. A foreign operator serving Korean users can face all three at once, each with its own trigger, its own filing, and its own penalty structure. The FIU's published criteria for when a foreign operator is treated as targeting the Korean market — a Korean-language interface, Korean-won settlement, marketing directed at Korean users, with the regulator noting that a determination can be made even without the first two — are the place to start in working out whether these regimes reach you at all. Working out which of them do, and in what order, is the tractable version of the problem — and it is better done against the August text than the one it replaces.

Munteok provides regulatory information, not legal advice.