Cha & Kwon Law Offices advised an overseas virtual asset exchange operator on regulatory issues arising from the domestic implementation of the OECD’s Crypto-Asset Reporting Framework (CARF), focusing on implementation timelines, scope of application, and potential reporting obligations based on nexus with Korea.
 
Key issues included the timing of Korea’s CARF adoption, the scope of reporting crypto-asset service providers, customer due diligence and transaction reporting requirements, and the potential applicability of CARF to overseas exchanges. In particular, the firm examined whether Korean-language marketing activities or user accessibility alone could trigger reporting obligations under Korean CARF regulations.
 
Based on the text of the CARF implementation rules and OECD guidance, Cha & Kwon Law Offices analyzed reporting nexus criteria such as the existence of a permanent establishment, place of management, or local entity in Korea. The advisory also outlined timeline-based compliance considerations and reviewed response trends among major domestic and international exchanges to provide comparative regulatory benchmarks.
 
As a result, the firm advised that the mere presence of Korean users or website accessibility does not automatically give rise to CARF reporting obligations, while also identifying structural and operational changes that could expand regulatory exposure and providing practical guidance for phased compliance planning.