Promoting Bybit Coin Referrals Is Now Risky — Illegality Concerns Are Real
1. Why Coin Referrals Are Becoming a Serious Legal Issue
In recent virtual asset–related investigations, referral structures such as Bybit coin referrals have been repeatedly scrutinized. This trend stems from the clear stance taken by the Financial Services Commission (FSC) and the Financial Intelligence Unit (FIU).
The FIU has consistently emphasized that it is, in principle, illegal for unreported virtual asset service providers (VASPs) to solicit, broker, or intermediate transactions for Korean residents, or to support KRW-based payments.
At present, only 27 operators have completed official registration in Korea. If domestic or overseas platforms not included on this list operate Korean-language websites, provide KRW deposits or withdrawals, or conduct promotions targeting Korean users, they face a substantial risk of violating the Act on Reporting and Using Specified Financial Transaction Information (the “Specified Financial Information Act”).
This standard applies equally to overseas exchanges if they target Korean residents. The core issue, however, lies in the lack of a clearly defined boundary as to what constitutes “virtual asset service provider activity.”
Because enforcement authorities assess factors such as repetition, fee structures, and the scope of customers on a comprehensive basis, the line between mere personal use and business activity remains blurred. In this environment, investigative risks are rapidly expanding—and coin referral structures have increasingly come under scrutiny.
2. What Bybit’s Recent Announcement Signifies
Bybit’s recent official compliance announcement carries significant implications.
The exchange made clear its intention to strengthen a global compliance framework aligned with local regulations and to allow marketing, promotion, and user solicitation only in jurisdictions where regulatory requirements are satisfied.
With respect to Korea, Bybit explicitly addressed the risks associated with unregistered marketing and intermediary activities, including brokerage-like conduct. It prohibited referral and commission-based structures that specifically target Korean users.
Bybit further stated that it is restricting referral and commission-based promotional activities aimed at Korea, and that if such activities are identified, partnership termination and commission clawbacks may follow.
This indicates that even overseas exchanges now recognize Korean-targeted referral schemes, such as Bybit coin referrals, as a clear regulatory risk and are beginning to draw firm boundaries.
3. Structures That Law Enforcement Authorities Actually Focus On
In practice, referral activities are rarely assessed in isolation. Instead, they are evaluated in conjunction with other transactional structures.
For example, when repetitive P2P or OTC transactions are conducted through Telegram or open chat rooms, and a fee structure exists alongside repeated trades, such activity is likely to be classified as “transactions conducted for business purposes.” In several cases, this has led to violations of the Specified Financial Information Act.
Similarly, currency exchange structures exploiting the so-called “Kimchi premium” may pose relatively low risk if limited to simple arbitrage. However, when combined with false invoices or quid pro quo remittances, they can give rise to violations of the Foreign Exchange Transactions Act, the Specified Financial Information Act, and even obstruction of business charges.
Within this context, inducing users to open accounts on unregistered overseas exchanges and receiving transaction-volume–linked commissions—such as in Bybit coin referral schemes—may be deemed to involve elements of brokerage, intermediation, or agency, making them potential targets of investigation.
Although standalone precedent is limited, cases in which such conduct is combined with investment solicitation or deceptive practices frequently escalate into criminal matters. A single act that was previously taken lightly can be interpreted as a critical link in a serious criminal scheme—this risk should never be underestimated.
4. Decent Law Firm’s Support in Virtual Asset Investigations
In Bybit coin referral–related cases, outcomes often hinge on what is properly organized and clarified at the earliest stage.
If factors such as transaction frequency and repetition, the existence of a commission structure, the scope of counterparties, awareness of fund sources, and one’s actual role are not systematically analyzed, even a minor matter can expand into allegations of participation in a serious criminal offense.
For those facing uncertainty and anxiety at this stage, practical and experience-based legal assistance is essential.
Decent Law Firm analyzes key issues by integrating FSC and FIU materials and guidelines, investigative practices, and recent case law, carefully assessing whether a client may be deemed a virtual asset service provider and whether the matter could be linked to other criminal offenses.
We provide comprehensive support—from interview and statement strategies at the investigation stage, through warrant proceedings, to substantiation and defense at trial—going beyond advisory services to help design the overall structure of the investigation response.
If you have received a request for appearance or are facing a search and seizure, this moment is critical.
If you are concerned about issues related to Bybit coin referrals, this is not a matter to be taken lightly. Decent Law Firm’s Virtual Asset Task Force will stand with you throughout the process.
Haru Invest 
Legal Opinion
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