Dohun “Dean” Kim
A dean@decentlaw.ioDean built his legal expertise through in-house counsel roles at Hyundai Corporation and iM Securities, where he handled a broad range of corporate and financial regulatory matters. He specializes in capital markets, corporate restructuring and insolvency, and international transactions.
- VC · Financial Advisory
- Cross-border · Dispute Resolution
- Corporate · Startups
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- Rehabilitation · Bankruptcy
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법률정보Mandatory 'AI Content Labeling System' Starting 2026: An Essential Guide for Businesses and Marketers
With the rapid advancement of AI technology, marketing strategies utilizing virtual humans or AI-generated content have become commonplace. In response, to prevent consumer confusion and establish a sound market order, the government is set to fully implement the ‘AI Content Labeling System’ starting January 2026. This column summarizes the key aspects of the AI Labeling System—including its background, legal basis, practical labeling methods, and risks of non-compliance—that corporate marketing managers and influencers must be aware of. 1. Background: Preventing Misinformation and Market Disruption The primary reason for enforcing the AI Labeling System as a legal obligation is the surge in false and exaggerated advertisements exploiting AI technology. The "Fake Expert" Problem: There has been an increase in cases where fake doctors or experts created via deepfake technology recommend unverified products, hindering consumers' rational choices and causing financial damage. Establishing Market Order: The government has defined these practices not merely as marketing but as "acts disturbing market order." Consequently, it has mandated the disclosure of AI generation (e.g., "This content was created by AI") to ensure consumers can clearly identify the authenticity of information. 2. Legal Basis and Key Provisions The AI Labeling System is not a simple recommendation but a strong legal obligation based on the following laws: Category Key Provisions Note Framework Act on AI Effective Jan 22, 2026. Mandates labeling and notice for high-impact and generative AI services. Administrative Fines IT Network Act Requires uploaders to label AI content and imposes management/notice responsibilities on platforms. Amendment targeted for Q1 2026 Labeling & Advertising Act Regards concealing or exaggerating AI use as Unfair Labeling/Advertising. Punitive Damages In particular, the Fair Trade Commission (FTC) plans to strictly sanction AI Washing—the act of concealing the use of AI to make content appear human-created—viewing it as deceptive advertising. 3. Practical Guide: Who, What, and How to Label 1) Obligated Parties: AI Business Operators Under the law, the obligated parties are defined as "AI Business Operators." This encompasses not only AI technology developers but all business entities (corporations, organizations, and individuals) that provide products or services utilizing AI. 2) Content Subject to Labeling Generative AI Products/Services: Prior notice is mandatory when providing AI-based services such as chatbots or image generation tools. Deepfake Results: Virtual audio, images, or videos that are difficult to distinguish from reality. Advertising Content: AI-generated content for commercial purposes, such as shopping mall detail pages and influencer sponsored ads. 3) Labeling Methods and Exceptions General Principle: Must be labeled in a way that consumers can clearly recognize (e.g., subtitles, watermarks, etc.). Cultural/Artistic Exception: However, if the content qualifies as a "artistic or creative expression" and labeling would significantly hinder appreciation, flexible labeling exceptions may apply (Article 31, Paragraph 3 of the Framework Act on AI). 4. Penalties and Risks (Fines vs. Damages) Sanctions for violating the AI labeling duty are divided into administrative sanctions (fines) and civil liability (damages). ① Violation of the Framework Act on AI: Administrative Fines If an AI business operator fails to comply with the labeling duty or fails to notify the production of deepfakes, they will receive a corrective order from the Minister of Science and ICT. Failure to comply may result in an administrative fine of up to 30 million KRW. ② Violation of the Labeling & Advertising Act: Punitive Damages Beyond simple failure to label, if the act involves malicious false or exaggerated advertising (e.g., using fake experts), the Fair Labeling and Advertising Act applies. Current: Liability for damages up to 3 times the amount of damage. Proposed Amendment: The government is pushing for an amendment to increase this limit to up to 5 times to eradicate market disturbance. 5. Conclusion and Response The AI Labeling System is not a regulation saying "Do not use AI," but rather a standard of trust requiring "Transparency if AI is used." With the January 2026 implementation approaching, companies must review their internal compliance processes to prevent unnecessary legal disputes. The Corporate Law Team at Decent Law Firm provides professional assistance regarding AI and IT-related legal advisory and compliance system construction. Please feel free to contact us if you have any inquiries.
2026-01-07 -
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Decent Law Firm Conducts 6th Compliance and Ethics Training on Virtual Assets for Crypto Media Group
Decent Law Firm announced that on October 21, 2025, it delivered the 6th Virtual Asset Compliance and Ethics Training program for the executives and employees of Crypto Media Group Co., Ltd. This training was designed as a practical program aimed at preventing legal risks in the virtual asset industry while strengthening corporate ethical decision-making frameworks and internal control systems. The session was held offline at Decent Law Firm’s headquarters, with key operational staff from Crypto Media Group in attendance. Discussions focused on legal standards and response strategies that can be applied immediately in day-to-day operations. The training covered major legal and ethical issues frequently encountered in the virtual asset sector, including legal risks relating to cryptocurrency transactions, duties of good faith and contractual performance, protection of internal information and conflict-of-interest management, and legal standards for determining fraudulent practices. It also incorporated key provisions of the Virtual Asset User Protection Act, the Capital Markets Act, and the Act on Reporting and Using Specified Financial Transaction Information (the “AML Act”), along with an overview of the principal issues under the proposed Digital Asset Framework Act currently pending before the National Assembly. Based on these laws, the session provided concrete operational guidelines and internal control measures for running a compliant and transparent virtual-asset business. Mr. Seonghwan Kim, CEO of Crypto Media Group, stated, “As the virtual asset industry continues to integrate into the regulatory mainstream, enhancing compliance awareness among our employees and partners is essential to maintaining corporate trust. We plan to strengthen our risk-management systems and conduct regular training in cooperation with Decent Law Firm.” Mr. Hyunsoo Jin, Managing Partner of Decent Law Firm, added, “The virtual asset industry remains in a transitional period where legal standards are still developing. During such times, it becomes even more important for businesses to establish their own compliance principles and operate responsibly within clear boundaries.” Decent Law Firm provides specialized advisory and dispute-resolution services to domestic and global exchanges, Web3 projects, and investment firms across virtual assets, blockchain, and cross-border transactions. Building on this training program, the firm plans to further expand its regular compliance-education offerings to promote a culture of voluntary compliance and responsible governance in the virtual asset industry.
2025-10-27
