Hana Bank Would Be a Virtual Asset Service Provider (VASP) As Hana Bank Bets 1 Trillion Won on Dunamu, the Operator of Cryptocurrency Exchange Upbit
Virtual asset service provider (VASP) must report any changes in its major shareholder composition to the Financial Intelligence Unit (FIU) under current law.
Hana Bank’s emergence as a major shareholder in Dunamu, the operator of cryptocurrency exchange Upbit, is raising questions over whether the company must file an updated virtual asset service provider report.
By entering the major shareholder ranks of Dunamu, Hana Bank has placed itself under scrutiny by financial regulators. The move is expected to serve as a key barometer for the future of the financial-crypto separation policy, an unwritten rule that has effectively barred combinations between traditional financial institutions and the virtual asset industry.
According to the cryptocurrency industry on May 21, the Financial Intelligence Unit (FIU) recently requested a legal interpretation and opinion from its parent agency, the Financial Services Commission, regarding Hana Financial Group’s acquisition of a stake in Dunamu.
Earlier, Hana Bank disclosed that it would purchase 2.284 million shares in Dunamu from Kakao Investment. The deal, valued at 1.0032 trillion won, equivalent to $667.29 million, has drawn significant attention from both the traditional financial sector and the cryptocurrency industry. Once the acquisition is completed on June 15, Hana Bank will secure a 6.55 percent stake in Dunamu, instantly becoming its fourth-largest shareholder. Meanwhile, Kakao Investment’s stake will fall from 10.58 percent to 4.03 percent, pushing it out of the top five shareholders.
Under current law, a virtual asset service provider (VASP) must report any changes in its major shareholder composition to the FIU. The reporting requirement was introduced after supervisory regulations under the Act on Reporting and Using Specified Financial Transaction Information were revised in 2024 to mandate disclosure of major and largest shareholders. A major shareholder is defined as an entity holding 10 percent or more of voting shares or effectively exercising influence over management through the appointment and dismissal of executives.
Accordingly, Dunamu must notify the FIU that Kakao Investment is no longer classified as a major shareholder. In addition, if Hana Bank personnel later join Dunamu’s management as registered executives, the company will also need to file a separate executive change report. A financial regulatory official said that both the entry and exit of major shareholders are subject to change reporting and that a post-review process will begin once the filing is submitted.
Industry attention is now focused on how regulators will apply the so-called separation principle between finance and virtual assets to the transaction. Although the principle is not formally codified in law, it has effectively functioned as a shadow regulation since emergency cryptocurrency measures introduced in 2017 established a policy of prohibiting traditional financial institutions such as banks and securities firms from investing in virtual asset businesses.
Earlier this year, when Mirae Asset Group acquired a 92.06 percent stake in the crypto exchange Korbit, whether the financial-crypto separation rule would apply became a major point of debate. However, because the buyer was Mirae Asset Consulting, a non-financial affiliate, analysts said the deal avoided direct application of the restriction, and the FIU approved Korbit’s executive change filing after three months.
This time, with a core banking unit of a financial holding group directly participating in the transaction, the deal is expected to become a key test case for regulators’ stance. An industry official said that while the controlling shareholder is not changing, authorities are likely to examine the matter more cautiously given the involvement of a commercial bank and the planned partnership between Naver and Dunamu, among other interested parties.
Lee Song-hoon
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