A bill amending the Act on Reporting and Using Specified Financial Transaction Information — Korea's core AML/reporting statute for virtual asset service providers (VASPs) — has been introduced in the National Assembly. As drafted, the amendment would apply to VASPs and other reporting obligors under the Act on a case-by-case basis, with no fixed quantitative threshold, and would reach providers serving Korean users regardless of whether they maintain a domestic presence. No effective date or penalty figure has been set; the bill has not yet passed and is not in force.
What this means for you
- Check applicability now, not later. If your service is used by Korean customers, the draft's language reaches you regardless of domestic incorporation — the usual "no Korean entity, no exposure" assumption does not hold here.
- There is no threshold test to run yet. The bill contemplates a case-by-case (종합판단) standard rather than a bright-line revenue or user count, so a simple numbers check will not tell you whether you're in scope. Treat this as a qualitative review, not a threshold calculation.
- Nothing is due today. No effective date, penalty amount, or specific reporting procedure has been finalized. Do not implement changes based on unconfirmed figures.
- Track the bill's progress. Because the standard is discretionary and the bill is still moving through the legislative process, the scope and compliance mechanics could shift materially before enactment. Revisit this once committee review produces a settled text.
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