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Korea’s Suspicious Account Transaction Freeze System: What Scam Victims and Account Holders Need to Know
Since June 30, 2026, financial institutions in Korea have been able to promptly restrict transactions involving accounts suspected of being used in emerging phishing schemes, including no-show scams and romance scams. Victims should report the incident before the funds are transferred elsewhere. At the same time, an account holder whose account has been frozen despite receiving legitimate payment must be prepared to prove the underlying transaction with objective evidence. What Is the Suspicious Account Transaction Freeze System? Korea’s 「Special Act on the Prevention of Loss Caused by Telecommunications-Based Financial Fraud and Refund for Losses」 provides procedures for freezing accounts used in voice phishing schemes and refunding eligible victims. However, fraudulent schemes disguised as ordinary transactions involving goods or services have generally fallen outside the scope of the conventional voice phishing refund framework. This created practical difficulties in promptly restricting accounts used in scams presented as product purchases, investments, or service transactions. To address this issue, the Financial Services Commission, the Korea Financial Intelligence Unit, and the National Police Agency introduced a system on June 30, 2026, allowing suspicious accounts linked to emerging phishing schemes to be temporarily restricted through existing customer due diligence procedures. Once an account is identified as potentially connected to such a scheme, the financial institution may classify the account holder as subject to enhanced customer due diligence under the 「Act on Reporting and Using Specified Financial Transaction Information」 and restrict incoming and outgoing transactions. What Types of Scams May Be Covered? The system may apply to various forms of emerging phishing fraud, including the following. ▪️No-Show Scams A fraudster impersonates a public institution or corporate buyer, promises a large order, and instructs the victim to purchase goods or materials from a designated supplier. ▪️Romance Scams A fraudster builds a personal relationship through social media or messaging applications and later requests money for investments, business expenses, customs charges, medical costs, or similar reasons. ▪️Investment Scams A fraudster promises profits from stocks, virtual assets, overseas futures, or other investments, receives funds from the victim, and then blocks withdrawals or demands additional payments. However, an account is not automatically frozen simply because money was transferred and a dispute later arose. Authorities must distinguish between an ordinary contractual dispute and conduct involving deception through telecommunications and circumstances indicating possible fraud. Financial institutions and the police may review transaction records, communications, the method used by the suspected offender, and whether the promised goods or services were actually provided. How Does the Transaction Freeze Process Work? 1. Victim Report and Temporary Action by the Financial Institution A person who suspects that they have been targeted by an emerging phishing scam should immediately report the matter by calling 112 or visiting a nearby police station in Korea. A financial institution may take temporary action when it identifies a suspicious transaction through its fraud detection system or receives a report from the victim or the police. The account may therefore be temporarily restricted before the authorities have conclusively determined whether the case involves conventional voice phishing or another form of emerging phishing fraud. 2. Police Review of the Fraud Type The National Police Agency’s Integrated Response Center for Telecommunications Financial Fraud reviews whether the transaction involved a genuine sale of goods or services and examines the specific method used by the suspected offender. When the case is classified as conventional voice phishing, the existing account freeze and victim refund procedures under the telecommunications financial fraud legislation may apply. When the case is classified as an emerging phishing scheme, the relevant account may instead be placed under enhanced customer due diligence procedures. 3. Temporary Transaction Freeze for Seven Business Days Once the account is identified as being connected to an emerging phishing scheme, the financial institution may temporarily restrict both incoming and outgoing transactions. The Korea Financial Intelligence Unit then reviews the transaction history and the relationship between the victim and the account holder within seven business days of receiving the report. 4. Additional Freeze of Up to 60 Business Days When the Korea Financial Intelligence Unit determines that the restriction should remain in place, the financial institution may continue the freeze for an additional 30 business days after the initial seven-business-day period. At the request of the police, the restriction may be extended once for another 30 business days. During this period, the police may investigate the account’s connection to the suspected crime and trace the movement of funds. An Account Freeze Does Not Automatically Guarantee a Refund A suspicious account transaction freeze is intended to prevent funds from being transferred out of an account believed to have been used in a fraudulent scheme. It does not mean that the victim is automatically entitled to an immediate or full refund. In conventional voice phishing cases, the statutory process for extinguishing the account balance and refunding eligible victims may apply. By contrast, a transaction freeze involving an emerging phishing scheme relies on customer due diligence measures under Korea’s financial transaction reporting legislation. It therefore operates differently from the statutory refund process applicable to conventional voice phishing cases. The method and likelihood of recovery may depend on factors including: ▪️The amount remaining in the account ▪️The number of victims ▪️The nature of the suspected fraud ▪️The outcome of the criminal investigation ▪️Whether the account holder or another participant received or transferred the funds Depending on the circumstances, the victim may need to file a criminal complaint and separately consider a civil claim for unjust enrichment or damages against the account holder or the persons who participated in the fraud. Evidence Victims Should Preserve Delays in reporting may allow the funds to be transferred through multiple accounts, converted into cash, or exchanged for virtual assets. Rather than continuing to negotiate with the suspected offender, the victim should first consider reporting the matter and requesting that the relevant account be restricted. Important evidence may include: ▪️Bank transfer receipts, transfer dates, account numbers, and account holder names ▪️Text messages and conversations through KakaoTalk, Telegram, or other messaging services ▪️Screenshots of investment or trading platforms ▪️Requests for additional deposits, fees, or taxes ▪️Contracts, purchase orders, quotations, and business registration information ▪️Telephone numbers, social media accounts, and original files provided by the suspected offender Leaving a chatroom or replacing a mobile phone may make it difficult to preserve the original evidence. Victims should retain not only screenshots but also exported chat records, attachments, and original electronic files where possible. What If a Legitimate Business Account Is Frozen? A business may receive genuine payment for goods or services but still have its account reported as suspicious because the payment is connected to a broader fraudulent fund flow. Even when the underlying transaction was legitimate, restrictions on a business account may significantly affect payroll, supplier payments, and ordinary business operations. The account holder may raise an objection with the relevant financial institution or contact the National Police Agency’s Integrated Response Center for Telecommunications Financial Fraud at 1394. If the police determine that the account is unlikely to be connected to criminal activity, they may request that the financial institution lift the transaction restriction. A general statement that the payment came from a legitimate transaction may not be sufficient. The account holder should provide objective evidence demonstrating the commercial basis for receiving the funds. Relevant materials may include: ▪️Contracts and purchase orders ▪️Tax invoices, receipts, and payment records ▪️Delivery and receipt records ▪️Evidence showing that services were actually performed ▪️Communications with the customer or counterparty ▪️Records showing how the received funds were used ▪️Evidence explaining repeated or similar transactions If the account, debit card, password, or another means of account access was transferred or rented to another person, the matter may go beyond a simple transaction freeze and raise issues under Korea’s Electronic Financial Transactions Act. Similarly, withdrawing cash or transferring funds while knowing that the money was connected to a fraudulent scheme may result in an investigation for aiding and abetting fraud. The account holder should therefore organize the facts and supporting evidence from the earliest stage. Key Points for Responding to a Suspicious Account Freeze Victims of emerging phishing scams should report the incident promptly and preserve all transaction records and communications before the funds are transferred elsewhere. A person or business whose account has been frozen despite receiving legitimate payment should demonstrate the substance of the transaction and the lawful basis for receiving the funds through contracts, invoices, delivery records, and other objective evidence. Decent Law Firm assists clients with criminal complaints arising from emerging phishing scams, reviews potential avenues for recovering transferred funds, and advises account holders on objections to transaction freezes and related criminal investigations. This content is provided for general informational purposes only and does not constitute legal advice for any individual matter.
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The CATFI Rug Pull Case and Unfair Trading Under Korea’s Virtual Asset User Protection Act
Meme coins often attract investors because they can be launched relatively quickly and may experience sharp price increases within a short period. Decentralized exchanges, or DEXs, facilitate trades through smart contracts and automated protocols rather than a centralized order-matching system. Once a token has been issued, trading can begin by creating a liquidity pool without going through the formal listing review typically required by a centralized exchange. This structure can attract investors seeking early exposure to newly launched tokens. At the same time, there has been growing concern over so-called rug pulls, in which project operators use false or misleading information to drive up the price of a token and then sell their holdings all at once. In May 2026, the Seoul Southern District Prosecutors’ Office indicted individuals involved in the issuance of the meme coin CATFI on charges including violations of Korea’s Act on the Protection of Virtual Asset Users. Prosecutors alleged that the defendants circulated false positive announcements, manipulated the token’s trading activity, and obtained unlawful profits. The case was the first in which prosecutors applied the Act’s provisions on fraudulent unfair trading. This article examines the laws that may apply to rug pulls and the key legal issues arising from such cases. Laws That May Apply to Rug Pull Schemes A rug pull is not a separately defined criminal offense under Korean law. Depending on how the scheme was structured, several provisions may apply. Where false disclosures, artificial trading activity, or market manipulation are involved, Article 10 of the Act on the Protection of Virtual Asset Users, which prohibits unfair trading practices, may become relevant. Category Main Conduct Relevant Provision Use of material non-public information A virtual asset service provider, issuer, or other relevant party uses undisclosed material information for trading Article 10(1) Market manipulation through matched or wash trades Parties coordinate transactions in advance or conduct trades without a genuine transfer of economic ownership Article 10(2) Market manipulation through actual trades Trades are carried out to induce others to buy or sell by artificially moving the market price Article 10(3) Fraudulent unfair trading A person uses fraudulent means, schemes, or deceptive practices, or makes false statements about material facts Article 10(4) If the parties behind a rug pull used multiple wallets to trade among themselves and artificially inflate transaction volume, Article 10(2) may apply. If investors were attracted through false lock-up announcements, fabricated social media engagement, or other misleading representations, Article 10(4) may also become relevant. A violation of these provisions may result in imprisonment for at least one year or a fine equal to three to five times the profit obtained or loss avoided through the violation under Article 19(1). Where the unlawful profit or avoided loss is at least KRW 500 million but less than KRW 5 billion, the offender may be sentenced to imprisonment for at least three years. Where the amount is KRW 5 billion or more, the punishment may be life imprisonment or imprisonment for at least five years under Article 19(3). Separate from criminal penalties, the Financial Services Commission may also impose an administrative surcharge in connection with unfair trading conduct. Administrative sanctions and criminal proceedings are legally distinct and may be pursued through separate procedures. The CATFI Case and the Legal Test for a Rug Pull According to the prosecution, the individuals involved in CATFI divided their holdings across multiple wallets and announced a lock-up plan on social media even though the promised restrictions were not actually observed. An influencer allegedly presented himself as an independent third party with no connection to the issuing group and encouraged investors to purchase the token. The defendants were also accused of using multiple wallets to create the appearance of active trading and rising demand. Once purchases by ordinary investors increased, they sold their holdings in a large-scale disposal. The token reportedly increased in value by approximately 1,001 times within 26 hours of issuance. Around 6,000 individuals purchased the token, and 256 investors were found to have suffered losses totaling approximately KRW 900 million. Prosecutors alleged that the defendants used approximately KRW 10 million in initial funds and obtained roughly KRW 400 million in sale proceeds. At the first trial hearing held on June 30, 2026, the defendants admitted the charges. Prosecutors requested a sentence of four years and six months for the influencer alleged to have led the scheme. However, a sharp decline in a token’s price or the failure of a project does not automatically establish a criminal rug pull. Virtual asset investments inherently involve price volatility. It is therefore necessary to distinguish between a genuine business failure and a scheme designed from the outset to deceive investors and extract funds. In practice, investigators may examine whether: ▪️ The parties had planned to sell their holdings before the token was issued or concealed the true amount held by the project team ▪️ Lock-up or token-burning plans were falsely announced, or holdings were distributed across multiple wallets to disguise common ownership ▪️ Trading volume and price movements were artificially created, followed by the closure of social media channels or online communities immediately after the sale Key Legal Issues and Response Options 🔹Criminal Liability of Influencers and Marketing Personnel A person does not avoid criminal liability simply because they did not personally issue the token. An influencer, marketing agency, or account operator may be investigated as a principal offender or an accomplice if they coordinated with the issuing group, published false information, or recommended the token while falsely presenting themselves as an independent third party. Relevant evidence may include: ▪️ Records showing that tokens were transferred to the promoter before the marketing campaign ▪️ Messages concerning the sharing of sale proceeds or trading profits ▪️ Records showing that promotional content was published despite knowledge that the information was false These materials may be important in determining whether the person merely provided advertising services or knowingly participated in the scheme. 🔹Options for Investor Recovery Article 10(6) of the Act on the Protection of Virtual Asset Users provides that a person who violates the unfair trading provisions may be liable for losses caused to users by the violation. Accordingly, investors may consider a civil claim for damages separately from any criminal complaint or prosecution. In practice, however, recovery may be difficult where the issuer operated through anonymous wallets. Identifying the responsible parties and proving a causal connection between the unlawful conduct and the investment loss can require a detailed review of both blockchain records and online promotional materials. Investors should therefore preserve relevant evidence as early as possible, including wallet addresses, transaction hashes, purchase records, social media posts, and announcements concerning lock-ups, listings, or partnerships. Decent Law Firm’s Virtual Asset Practice The CATFI case demonstrates that even where a meme coin is traded through a DEX, false announcements, coordinated trading, and artificial price movements may lead to liability under Korea’s Virtual Asset User Protection Act. It also shows that affected investors may need to consider both criminal proceedings and civil claims for damages. Decent Law Firm’s Virtual Asset Practice reviews on-chain transaction structures and blockchain fund flows in connection with rug pulls, market manipulation, criminal complaints, investigations, and civil damages claims. Where an investment loss appears to involve a rug pull or other unfair trading conduct, legal advice should be obtained at an early stage, beginning with the preservation and review of evidence. This content is provided for general informational purposes only and does not constitute legal advice for any specific matter.
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Refusing "Imuidonghaeng" (Voluntary Accompaniment) in Korea: Legal Requirements and How to Respond
A Korean police officer asking you to come to the police station "voluntarily" — known as imuidonghaeng (임의동행), or voluntary accompaniment — is a routine part of policing in Korea. But because it happens without a warrant, there is a lot of confusion about when it is lawful, and whether you can actually say no. The National Human Rights Commission of Korea has previously ruled that when police request voluntary accompaniment without informing the person that they have the right to refuse, this violates the constitutional right to personal liberty. This article explains the legal basis for voluntary accompaniment, the conditions that make it lawful, and what the courts have said about it. The Legal Basis The legal basis for voluntary accompaniment comes from two sources. Article 3 of the Act on the Performance of Duties by Police Officers allows an officer to question someone whose behavior is suspicious or who is reasonably suspected of a crime, and — if necessary — to request that the person come to a nearby police station. Importantly, this is only a "request." Paragraph 2 of the same article is written on the premise that the person may decline. The same article also contains several procedural safeguards: • Paragraph 5: If a person is brought in, the officer must notify the person's family or an acquaintance of the officer's identity, the location, and the purpose of the accompaniment — or give the person the chance to make that call themselves — and must inform them of their right to legal counsel. • Paragraph 6: A person cannot be kept at a police station for more than 6 hours as a result of voluntary accompaniment. • Paragraph 7: The person cannot be physically detained except under procedures set out in the Criminal Procedure Act, and cannot be forced to answer questions against their will. Article 199, Paragraph 1 of the Criminal Procedure Act establishes the principle that investigations should rely on voluntary methods, and that compulsory measures are only permitted where specifically authorized by law, and only to the minimum extent necessary. Even when investigators use the form of "voluntary" accompaniment, this principle still applies in substance. Category Legal Basis Can You Refuse? Stop-and-question (bulsimgeommun) Police Duties Act, Art. 3(1) No legal obligation to answer Voluntary accompaniment Police Duties Act, Art. 3(2); Criminal Procedure Act, Art. 199(1) Yes, in principle Arrest / detention Criminal Procedure Act, Art. 200-2 and following Cannot refuse if a warrant or statutory grounds exist Source: Act on the Performance of Duties by Police Officers; Criminal Procedure Act What the Courts Have Said The Supreme Court of Korea has set out the conditions under which voluntary accompaniment is considered lawful: "[Voluntary accompaniment to an investigative agency] is recognized as lawful only where it is objectively and clearly proven that the accompaniment took place based solely on the suspect's own free will — such as where the investigator informed the suspect, before the accompaniment, that they could refuse, or where the suspect was free to leave the accompaniment process or the location at any time." — Supreme Court, Judgment of July 6, 2006, Case No. 2005Do6810 In other words, if a person was not told they could refuse before being brought in, or could not realistically have left once there, the accompaniment may not be considered lawful — even if it was labeled "voluntary." In that case, the admissibility of any statements or evidence obtained afterward can also become a live issue. That said, refusing verbally and physically resisting are treated as legally distinct matters. In cases where a person responded to a lawful stop-and-question or accompaniment request with physical resistance or by fleeing, the resistance itself has been separately recognized as obstruction of official duties in some cases. Whether a refusal was expressed in a lawful manner depends heavily on the specific facts. Practical Issues to Consider The following points are worth keeping in mind if you are asked to accompany police voluntarily: • Whether the legal requirements were met: Whether you were told you could refuse, and whether you were genuinely free to leave, can determine whether the entire procedure was lawful. • How you express refusal: State your refusal clearly and, where possible, keep a record of the situation (for example, by recording audio). This can reduce disputes later. • The distinction between refusal and resistance: Verbal refusal and physical resistance are evaluated very differently under the law. A procedural response is far safer than an emotional one. • Your rights even if you do go along: Even if you agree to accompany police, the 6-hour limit and your right to legal counsel still apply. The specific outcome will always depend on the facts of the individual case and how the police handled the situation. About Decent Law Firm Because voluntary accompaniment happens before formal arrest or detention, how it is handled at this stage can affect the direction of the entire investigation that follows. The Criminal Defense Team at Decent Law Firm has experience advising on cases from the stage of stop-and-question and voluntary accompaniment through to trial. If you have been asked to accompany police, or if you believe the accompaniment was not lawfully conducted, we recommend reviewing your initial response before answering any questions. Decent Law Firm operates a 24-hour system in which a lawyer can respond and travel to the location directly, including at night.
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Livelihood-Based Objection for DUI License Suspension or Revocation in Korea: When Reduction May Be Excluded
If your driver’s license has been suspended or revoked due to DUI in Korea, you may file an objection with the competent metropolitan or provincial police agency within 60 days from the date you receive the disposition. One of the grounds for reduction is when driving is an essential means of supporting the applicant’s family. In practice, this is often referred to as a “livelihood-based objection.” However, even if driving is important for your work or livelihood, certain circumstances may exclude you from reduction from the outset. This article explains the legal basis of the livelihood-based objection and the key situations where a reduction may not be available. Legal Basis and Possible Effect of an Objection An objection against a driver’s license suspension or revocation due to DUI is based on Article 94 of the Korean Road Traffic Act and Articles 95 and 96 of the Enforcement Rule of the Road Traffic Act. The objection must be filed within 60 days from the date the disposition is received. Once filed, the case is reviewed by the Administrative Review Committee for Driver’s License Dispositions, which may decide whether the disposition can be reduced. The Enforcement Rule sets out several grounds for reduction. One of the most commonly used grounds is where driving is an essential means of maintaining the livelihood of the applicant’s family. If this ground is accepted, a license revocation may be reduced to a 110-day license suspension. A license suspension may also be reduced by up to one-half of the original suspension period. When Reduction May Be Excluded Before reviewing whether driving is necessary for livelihood, the authorities first check whether any exclusion grounds apply. Reduction may be excluded in the following cases: ▪️Blood alcohol concentration over 0.1% If the driver’s BAC exceeded 0.1% at the time of detection. ▪️Traffic accident involving personal injury If the DUI resulted in an accident where another person was injured. ▪️Refusal to take a breathalyzer test, fleeing the scene, or assaulting a police officer If the driver refused testing, fled, or used violence against an officer during enforcement. ▪️Repeated personal injury accidents within the past five years If the driver caused three or more traffic accidents involving personal injury within the past five years. ▪️Prior DUI record within the past five years If the driver has a previous DUI record within the past five years. Source: Appendix 28 of the Enforcement Rule of the Road Traffic Act These grounds apply independently. This means that even one applicable ground may exclude the applicant from reduction, regardless of how important driving is for work or family livelihood. Even a first-time DUI offender may be excluded if the BAC level exceeds the applicable threshold or if a personal injury accident occurred. What to Check Before Filing an Objection Before preparing a livelihood-based objection, it is important to review the following points in order. First, check the BAC level at the time of detection. If it exceeded 0.1%, reduction may be excluded. Second, check whether there was any accident, refusal to take a breathalyzer test, fleeing, or other aggravating circumstance. Third, if no exclusion ground applies, prepare documents showing that driving is necessary for maintaining livelihood. These may include an employment certificate, business registration certificate, client or delivery records, income documents, and other materials showing that driving is essential for work. If an objection is filed only with a statement of hardship, without first checking the exclusion grounds, the 60-day filing period may be used up without meaningful review. How Decent Law Firm Can Assist In livelihood-based DUI objections, the possibility of reduction does not depend only on whether the applicant is a first-time offender. BAC level, accident history, refusal to comply with testing, and prior DUI records are critical factors that determine whether reduction may be available at all. Decent Law Firm’s criminal defense team reviews DUI-related administrative dispositions, including objections and administrative appeals, from the initial stage. If you have received notice of license suspension or revocation in Korea, it is important to review your eligibility before the 60-day deadline expires.
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Overseas Futures Trading Lawyer: What You Need to Know Before an Investigation Begins
Why Domestic Promotion of Overseas Futures and FX Margin Trading Can Be Problematic Trading overseas futures or FX margin products is not, in itself, completely prohibited under Korean law. The issue arises when individuals or entities provide brokerage-related services or facilitate such trading activities within Korea without the required authorization. Under the Financial Investment Services and Capital Markets Act ("Capital Markets Act"), any person engaging in the business of trading, brokerage, or intermediation of financial investment products must obtain authorization from the Financial Services Commission. Overseas futures and FX margin products are classified as derivatives under the Capital Markets Act. Depending on the manner and extent of a person's involvement, different offenses and penalties may apply. For example, legal issues may differ depending on whether a person: Assists clients in opening accounts on overseas platforms such as MT4 or MT5; Operates a trading signal or "copy-trading" community; Receives and manages client funds directly. Case Study: “I Only Helped Connect People to the Platform” Mr. A had traded overseas futures for several years and built a track record of profitable trading. As his results became known among acquaintances, several people expressed interest in participating. Mr. A began assisting them with MT5 account registration and deposit procedures. He later operated a KakaoTalk group chat and Telegram channel where he provided real-time trading signals and received monthly subscription fees from members. Mr. A believed that he was merely providing information because each customer opened and managed their own account. His position was simple: "The investment decisions were made by the customers themselves." However, he eventually received notice that he had become the subject of a Financial Supervisory Service (FSS) investigation, which later developed into a criminal investigation. Investigators concluded that Mr. A's conduct went beyond merely providing market information. They focused on the fact that he continuously communicated with members in real time and repeatedly instructed them on entry and exit points for trades in exchange for compensation. When evidence emerged suggesting direct involvement in certain members' trading accounts, the allegations became significantly more serious. Why “Providing Information Only” Can Still Lead to Violations of the Capital Markets Act This is where many people misunderstand the legal risks. As involvement becomes more substantial, the potential offenses become more serious. Investigators typically focus on factors such as the following: Commercial Nature of the Activity Did the operator repeatedly collect fees while promoting services to the general public? → Potential issue: Violation of regulations governing quasi-investment advisory businesses Interactive Communication Did the operator provide individualized trading recommendations through open chat rooms, Telegram channels, or similar platforms? → Potential issue: Unregistered investment advisory business Automated Trading Execution Did the operator use API integrations or copy-trading systems that automatically replicated trades for clients? → Potential issue: Operating an investment discretionary management business without registration Involvement in Client Funds Did client funds pass through the operator's accounts, or did the operator directly participate in the trading process? → Potential issue: Unauthorized investment brokerage business Since August 2024, Korean regulations have prohibited quasi-investment advisory businesses from operating interactive communication channels with subscribers. This is one reason why the argument that someone was "only providing information" may no longer be persuasive from the outset. Additional Charges Such as Illegal Fundraising and Fraud May Also Apply If investors were recruited using representations such as: "Guaranteed monthly returns" "No risk of principal loss" "Guaranteed profits" additional criminal liability may arise under the Act on the Regulation of Conducting Fund-Raising Business Without Permission. This law prohibits raising funds from an unspecified number of individuals while promising repayment of principal, interest, or other guaranteed returns without proper authorization. Where an operator attracts investors through a trading signal service or investment community while emphasizing guaranteed profits, authorities may pursue multiple charges simultaneously, including: Violations of the Capital Markets Act; Violations of laws regulating unauthorized fundraising activities; Fraud. For example, in 2025, the Gyeonggi Nambu Provincial Police Agency arrested 28 individuals accused of raising approximately KRW 140 billion from more than 2,400 investors by claiming they would generate profits through FX margin trading. Authorities reportedly applied charges including fraud, illegal fundraising, and violations of the Door-to-Door Sales Act. This illustrates why overseas futures and FX margin trading cases rarely involve only a single allegation. What to Review If You Have Been Contacted by Investigators If any of the following situations apply to you, legal review before questioning may be advisable: ▪ Providing paid overseas futures or FX margin trading signals through Telegram, KakaoTalk, or similar platforms; ▪ Assisting clients with MT4, MT5, or similar platform account openings while receiving commissions or referral fees; ▪ Operating copy-trading services using clients' API keys or automated trading systems. Depending on the specific facts, authorities may allege: Violations relating to quasi-investment advisory businesses; Unregistered investment advisory activities; Unregistered investment discretionary management services; Unauthorized investment brokerage; Illegal fundraising activities; Fraud. The direction of statements made during the early stages of an investigation can significantly influence the development of the case. Understanding the legal structure of the allegations before attending an interview is therefore critical. The Digital Asset Practice Team at Decent Law Firm regularly advises individuals and businesses involved in investigations concerning unauthorized overseas futures and FX margin trading activities. If you have been contacted by investigators or have already been scheduled for questioning, it is important to understand the nature of the allegations and the overall structure of the case before appearing for an interview.
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Accomplice Liability in Drug Cases Involving Privacy Coins: Dark Coins, Crypto Payments, and Investigation Risks in Korea
Why Are Privacy Coins Used in Online Drug Transactions? Monero (XMR), Zcash (ZEC), and similar assets are commonly referred to as privacy coins or “dark coins.” Unlike Bitcoin or Ethereum, where transaction records are generally visible on public blockchains, Monero is designed to make it difficult to identify the sender, recipient, and transaction amount through technologies such as ring signatures and stealth addresses. For this reason, Monero and other privacy-focused assets are sometimes used in online drug transactions, including transactions arranged through Telegram, dark web forums, and social media platforms. However, the fact that a transaction is difficult to trace does not mean that it is beyond the reach of law enforcement. Korean investigative authorities do not rely solely on on-chain transaction data. They may also review Telegram messages, mobile device forensic data, statements from sellers and buyers, exchange records, fiat conversion history, and other evidence to identify those involved in the transaction. In other words, privacy coins may make an investigation more complex, but they do not make an investigation impossible. Key Korean Laws That May Apply In drug-related cases involving privacy coins, multiple laws may apply depending on the person’s role and level of involvement. Legal Basis Main Conduct Covered Possible Penalty Narcotics Control Act, Article 60(1)2 Sale, brokerage, receipt, possession, or use of certain psychotropic substances, including substances classified under Schedules B or C Imprisonment for up to 10 years or a fine of up to KRW 100 million Narcotics Control Act, Article 58(1)3 Manufacturing, import/export, sale, brokerage, receipt, or possession for such purposes of Schedule A psychotropic substances Life imprisonment or imprisonment for at least 5 years Act on Reporting and Using Specified Financial Transaction Information Operating a virtual asset business without the required VASP registration Imprisonment for up to 5 years or a fine of up to KRW 50 million Act on Regulation and Punishment of Criminal Proceeds Concealment Concealing or disguising proceeds from drug-related crimes Imprisonment for up to 5 years or a fine of up to KRW 30 million Even if a person did not directly sell or possess drugs, liability may still arise if they connected buyers and sellers, facilitated payment flows, exchanged virtual assets, or helped conceal criminal proceeds. In addition, if a person operates an over-the-counter (OTC) virtual asset service without proper registration and the service is used to process drug-related funds, separate issues may arise under Korea’s anti-money laundering and virtual asset regulations. The applicable law and potential penalty will depend on the type of substance involved, the exact conduct, whether the conduct was repeated, whether any compensation was received, and whether the person knew or should have known the criminal nature of the transaction. Crypto-Related Drug Investigations Are Expanding in Korea Drug transactions in Korea are increasingly moving from offline channels to online platforms such as Telegram, dark web marketplaces, and social media. According to media reports citing Korean police data, from January to April 2026, 9.2% of all drug offenders were reported to have used virtual assets. This was higher than the annual figure of 8.4% recorded in the previous year. The proportion of online drug offenders has also continued to rise. Media reports indicate that the figure increased from 24.0% in 2021 to 42.0% during the January–April 2026 period. Korean authorities are also strengthening their investigative infrastructure. In 2026, the Ministry of Science and ICT and the Korean National Police Agency began promoting a project to develop an integrated investigation system linking dark web activity, virtual asset transaction tracing, and online drug advertisement monitoring. The police have also established dedicated virtual asset investigation teams in major regional police agencies, including Seoul, Busan, Incheon, Gyeonggi Nambu, and Gyeongnam. As a result, crypto-related drug investigations in Korea are no longer limited to the question of whether a coin transaction can be traced on-chain. Investigators may analyze online communications, wallet and exchange records, fiat conversion records, device forensics, transaction patterns, and statements from co-suspects together. Using a Privacy Coin Does Not Prevent Accomplice Liability In a Korean drug investigation, the key issue is not simply the payment method. The more important question is how the person was involved in the drug transaction. The Narcotics Control Act does not only punish direct sales. It may also punish inducement, solicitation, brokerage, receipt, possession, use, importation, and manufacturing, depending on the substance and conduct involved. For example, methamphetamine is generally treated as a Schedule B psychotropic substance under Korean law. If a person sells, brokers, receives, possesses, or uses methamphetamine, Article 60(1)2 of the Narcotics Control Act may apply, which provides for imprisonment of up to 10 years or a fine of up to KRW 100 million. If the case involves importation or manufacturing of methamphetamine, a more serious provision may apply. Under Article 58(1)6 of the Narcotics Control Act, manufacturing or importing/exporting certain Schedule B psychotropic substances may be punishable by life imprisonment or imprisonment for at least 5 years. This means that the applicable charge can vary significantly depending on whether the conduct involved simple use, possession, sale, brokerage, aiding and abetting, importation, or manufacturing. Therefore, if you are contacted by Korean law enforcement, the first question should not be “Which coin was used?” but rather “What specific charge is being investigated?” Why “I Only Introduced the Parties” May Not Be Enough In many cases, suspects say: “I did not sell the drugs myself.” “I never touched the drugs.” “I only shared a Telegram link.” “I only helped connect two people.” However, Korean drug laws do not only target the final seller. If a person connects a buyer and a seller, directs someone to a sales channel, shares sales posts, helps arrange payment, or receives a commission after the transaction, the conduct may be viewed as brokerage or aiding and abetting. The following circumstances may increase legal risk: Repeatedly sharing Telegram channel links Connecting potential buyers to sellers Receiving a commission after a transaction Receiving the commission in Monero or another virtual asset Maintaining repeated contact with buyers or sellers Being named in a statement by an arrested seller or buyer In particular, receiving compensation in a privacy coin may be interpreted as an attempt to avoid detection. As a result, saying “I only introduced the parties” may sometimes help explain limited involvement, but it can also be used as evidence that the person knowingly participated in the transaction structure. What Evidence Do Korean Investigators Review? In privacy coin drug cases, Korean investigators generally do not rely on blockchain data alone. They may review the following types of evidence. First, they may review Telegram, KakaoTalk, Discord, or other messaging records. Even if the server is located overseas, messages, deleted data, files, images, contact information, and login records may be recovered through forensic analysis if a mobile phone or computer is seized. Second, they may rely on statements from co-suspects. If a seller or buyer is arrested first, the person may identify intermediaries, brokers, or payment facilitators during questioning. In that situation, even someone who was not present at the actual transaction may become a suspect. Third, they may review virtual asset and exchange records. Even if the privacy coin itself is difficult to trace, exchange registration records, deposit and withdrawal history, fiat conversion records, and transactions involving other virtual assets may still be reviewed. Fourth, they may assess repetition and compensation. A one-time message may be viewed differently from repeated introductions, repeated sharing of sales channels, or commission-based involvement. Whether the person received payment can significantly affect how the conduct is characterized. Before attending an interview, it is important to distinguish between what the investigators may already have and what the person’s actual role was. What to Check Before Attending a Police Interview If you are contacted by Korean law enforcement, it may be risky to immediately state, “I did not know,” or “I did not sell anything.” Early statements are later compared with police interview records, seized digital evidence, forensic results, and statements from co-suspects. If your statement changes or conflicts with other evidence, even limited involvement may be interpreted more unfavorably. Before attending an interview, you should check: The specific charge listed in the summons or notice Whether you are being treated as a suspect or a witness Whether your phone, computer, or other device has been seized The scope of Telegram, KakaoTalk, Discord, or other message records Whether any virtual asset wallet or exchange account was used Whether any seller or buyer has already been arrested Whether any commission or payment was received Whether there is evidence of repeated introductions or referrals Depending on these facts, the case may remain a witness interview, or it may develop into a full criminal investigation involving brokerage, aiding and abetting, or other drug-related charges. Once an interview date is scheduled, it is important to prepare a clear and consistent statement strategy in advance. Early Legal Response Matters in Privacy Coin Drug Investigations Using Monero or another privacy coin does not mean that a person is safe from investigation. Korean authorities are increasingly analyzing online drug transactions through Telegram records, virtual asset transaction structures, exchange and fiat conversion records, forensic evidence, and statements from co-suspects. In drug cases, the applicable law and penalty can vary significantly depending on whether the allegation involves use, possession, sale, brokerage, aiding and abetting, importation, or manufacturing. How you explain your role in the transaction, whether you received compensation, and how you respond to digital evidence and co-suspect statements may affect the direction of the case. Decent Law Firm’s criminal defense team assists clients in drug investigations involving virtual assets, digital forensic issues, and alleged accomplice liability. If you have received a police summons in Korea in connection with Monero, privacy coins, Telegram drug transactions, or virtual asset payments, it is important to review your situation before attending the interview. This content is provided for general informational purposes only and does not constitute legal advice for any specific case.
