On May 18, 2026, the focus of Seoul's financial district was on what seemed like an ordinary equity acquisition. Hana Bank plans to take over a portion of Dunamu's shares held by Kakao Investment, which, after the transaction is completed, will result in Hana Bank holding approximately 6.55% of Dunamu's shares indirectly through this intermediary company—Dunamu is the parent company of Upbit, South Korea's leading cryptocurrency exchange. This structured arrangement quickly caught the attention of the Financial Services Commission (FSC) of South Korea. On the same day, multiple media outlets reported that the FSC's virtual asset-related department stated that the commission has started reviewing the transaction, clearly indicating that even if indirect equity stakes are acquired via an intermediary company, as long as the funds ultimately target enterprises related to the cryptocurrency trading platform, it will be regarded as an investment in the trading platform itself, subject to the same “financial and virtual asset separation” regulatory standards. An unresolved issue then emerged—was Hana Bank's action an attempt at regulatory arbitrage by seeking gaps in structural design under existing red lines, or a compliance test of the boundaries of old rules? Given that Korea's “financial and virtual asset separation” still mainly relies on regulatory guidelines and administrative rules, and the FSC has publicly emphasized that there are no plans to relax current regulations, this review, which has yet to reach a final conclusion, is seen as a critical demonstration event regarding whether traditional banks can approach cryptocurrency exchanges via equity paths, and how future collaboration models can be designed.

Hana Bank's Indirect Approach

Under the valid premise of “financial and virtual asset separation”, Hana Bank chose not to directly approach Upbit but instead focused on the intermediary ownership structure—Kakao Investment. According to reports from multiple media sources, the transaction arrangement involves Hana Bank acquiring a portion of Dunamu's shares held by Kakao Investment, which on the surface completes an investment in an investment institution, yet effectively allows this commercially significant bank within South Korea's financial system to bypass the sensitive label of direct shareholding in the trading platform and become an indirect shareholder of Upbit's parent company, Dunamu.

For Hana Bank, this path design is a result of meticulous weighing: on one hand, it cannot overtly breach the direct shareholding prohibition imposed by “financial and virtual asset separation”; on the other hand, it does not wish to entirely stand outside the cryptocurrency trading market, missing out on potential insights and influence over this key infrastructure. Through indirect shareholding, it can maintain a semblance of “distance” from the trading platform in form while substantively getting closer to Dunamu's decision-making and development trajectory, thus creating a narrow gap for itself between traditional finance and cryptocurrency asset infrastructure.

The 6.55% indirect shareholding ratio frequently mentioned by the media sits within a delicate range: it is far from enough to constitute control but is sufficient to leave a visible banking presence in the capital structure. For the relationship between a systemic commercial bank and the leading cryptocurrency trading infrastructure in its home country, this figure is not just a simple financial investment number; it symbolizes a watershed moment where traditional financial power formally enters the shareholder list of a trading platform, thereby capturing the attention of regulators, industry, and markets alike, serving as a crucial gauge for assessing the nature and impacts of this “indirect approach” effort.

Regulatory Warning: Indirect Shareholding Counts

The stance of regulators was explicitly articulated on May 18. The virtual asset-related department of the Financial Services Commission publicly responded that even through the “roundabout” method of holding shares in an intermediary company and subsequently holding equity in a virtual asset-related enterprise, it is still substantially regarded as an investment in the trading platform itself, and such indirect investments will be reviewed according to the same regulatory standards as direct shareholdings. In other words, Hana Bank did not disappear from the regulatory view simply because it is behind this “buffer wall” of Kakao Investment; its approximately 6.55% indirect shareholding in Dunamu will still be treated as a case of the bank's involvement in equity of a cryptocurrency exchange on the compliance assessment form.

More crucially, the relevant officials of the FSC reiterated during this timeframe that there are currently no plans to relax the principle of “financial and virtual asset separation” and no specific plans to amend or loosen it, which means that regulatory standards remain within the framework that has gradually tightened over the past few years. Under these circumstances, Hana Bank's meticulously designed equity path of “intermediary company—Dunamu—Upbit” is unlikely to be framed as an innovative structure not constrained by existing rules, but rather appears more as a pressure test to see if it can pass “substance over form” scrutiny within the established red lines.

The Gray Area of Separation Principle Remains Unresolved

South Korea's “financial and virtual asset separation” is not a complete framework written in law but is instead a principled requirement gradually built by regulatory bodies, such as the Financial Services Commission, through administrative guidelines and regulatory rules. There is currently no conclusion on the direction and strength of relevant specialized legislation; how detailed and stringent the “separation” will ultimately be written remains unclear to the market, which can only speculate the boundaries within regulatory tones and actual approvals.

In this state of the system, individual case reviews have devolved into practical “line-drawing tools.” Regulatory authorities often communicate to the market what can be tolerated and what will be rejected through the approval results of single transactions in the absence of comprehensive written laws: whether indirect shareholding is equivalent to direct investment, what kind of businesses are recognized as “virtual asset-related enterprises”, and before the texts are finalized, all these standards rely on individual approvals built on factual benchmarks. Meanwhile, traditional financial institutions worldwide commonly attempt to engage with the cryptocurrency industry through equity investments, business collaborations, and technical inputs. When these paths are introduced into the context of South Korea, they inevitably clash with the compliance gray area created by the “separation” principle—whether viewed as an investment in the trading platform itself or classified as “pure financial” allocations to intermediary companies and technology service providers relies heavily on how regulators draw lines in cases like Hana Bank, and this line will, in turn, reshape the possibilities for banks to approach the cryptocurrency industry through structured paths.

If Approved or Stopped, Who Wins and Who Loses

If this indirect shareholding is ultimately approved, the biggest beneficiary would ostensibly be Hana Bank: it will leverage the approximately 6.55% indirect equity to position itself on the side of Dunamu's “infrastructure machine”, entering the liquidity center established by Upbit’s high market share, gaining pricing power, information rights, and prospects for medium- to long-term business synergy. For South Korea's cryptocurrency financial infrastructure, this would mean that traditional banks embed themselves in the governance structure of a leading trading platform as shareholders rather than peripheral collaborators for the first time. Other large banks, which have historically preferred a “light asset” route focused on custody and compliance collaboration, would therefore face competitive pressure—whether to continue to observe from the sidelines or to be compelled to seek their own equity entry will be dictated by the outcome of this case.

If the transaction is rejected, it would affirm the regulatory logic emphasizing “financial and virtual asset separation.” Regulators would reaffirm to the market: whether through direct holdings or intermediary company structures, as long as it points to the trading platform, banks must not cross the line, pushing collaboration between traditional finance and cryptocurrency platforms back to paths involving custody, technology, and compliance services that do not involve equity. Hana Bank could adjust to a more typical business collaboration model, and other banks would likely translate their equity impulses into service contracts and technical inputs. Thus, the industry structure would continue to maintain a division of labor where “exchanges trade, and banks operate peripherally.” Whether approved or stopped, this review will be documented in institutional memos, serving as a critical reference for future evaluations by Korean financial institutions on whether and how to approach cryptocurrency equity through structured arrangements.

The Next Steps for Korean Banks and Exchanges

Hana Bank's indirect entry attempt lays bare the long-standing structural contradictions within South Korea's financial system: on one side, traditional banks are seeking new growth points in the rapid development of the cryptocurrency industry, preferring structured paths such as intermediary companies for regulatory arbitrage; on the other side, regulators have established rigid boundaries defined by the principle of “financial and virtual asset separation,” publicly affirming that they will not actively relax these in the short term. As of May 18, 2026, the FSC only stated that it is “under review” without providing conclusions, yet has made it clear that indirect shareholding and direct investment will be subject to the same standards. This means that regardless of whether the result is approval or rejection, it will be viewed as a key case of equity cooperation between banks and trading platforms not only in South Korea but also in other markets, inevitably compelling subsequent legislation to redraw lines between principles and realities. While a final conclusion is still pending and relevant written rules are still in development, banks, exchanges, and their advisors can only suppress the impulse for structural innovation and closely monitor every slight adjustment in regulatory tones and legislative processes, as the true boundaries will ultimately be confirmed in these subtle shifts.

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