Is Korea’s Crypto Market Truly a Fair Playing Field?

Prologue: Fairness and Protection—For Whom?

Regulatory discourse around the virtual asset market invariably begins with the words “fairness” and “protection.” Yet when we look at the recurring pattern each time news breaks—Mirae Asset’s reported acquisition talks with Cobit, or the possibility of overseas players such as Bybit, OKX, and Coinbase entering Korea through M&A—it is hard not to worry that this language is in practice reinforcing an already entrenched exchange-centric structure and oligopoly. On the surface it appears to apply the same yardstick to everyone, but as interpretive uncertainty at the implementation stage, approval delays, and asymmetries in access accumulate, the result is weaker new competition and a status quo that grows more entrenched under the banner of “fairness.”

In particular, structural rules now under discussion—such as a cap on major shareholders’ stakes at around 15% (or 15–20%)—could go beyond merely making new entry difficult and effectively block market realignment through M&A. Even if one understands the intent behind such regulation, a uniform cap of this kind undermines the expected returns of ongoing acquisition talks and future capital raising, reducing the incentive to even attempt such moves and thereby reinforcing incentives to preserve the current market structure.

The Gopax–Binance case illustrates this paradox more clearly. While the entry of new players like Bybit or OKX was blocked, Binance’s stake in Gopax was hampered by prolonged regulatory review, leaving it unable to play a meaningful role in the market for a long time and ultimately revealing a structural limit: “even when M&A is completed, it does not immediately spur market competition.” In a growth industry, strong drive and capital from major shareholders can be the engine that sparks competition—through better services, risk management, fee and product competition, and attracting investment and talent—rather than a mere ownership issue. When regulation neutralizes that drive for long periods, the choices and benefits available to market participants shrink.

Equally important is that virtual assets are not, by nature, a mature industry. Even in the United States, no single framework for the virtual asset market is settled; multiple bills and regulatory frameworks are competing, and norms continue to evolve through interaction with the market. In such a dynamically evolving market, the essence of competition lies in operators’ capabilities and their willingness to build trust through dialogue with the market. If regulation is designed to block that competition at the source, protection becomes the price of innovation and fairness becomes another name for barring entry.

This series therefore traces how Korea’s virtual asset market has taken shape as the current “entrenched, exchange-centric market,” and examines the path dependence and limits on competition that have been created along the way. It also contributes to the discussion of under what conditions overseas operators’ entry and M&A, and new service models, can become possible in the Korean market, and what evolving rules can satisfy both consumer protection and industrial competitiveness.

Series: Is Korea’s Crypto Market Truly a Fair Playing Field?

• Prologue: Fairness and Protection—For Whom? (this page)

• Part 1: KRW Market Concentration and the Shadow of Fair Competition – We examine how trading has become concentrated in the domestic KRW market (where assets are traded in the fiat currency won), solidifying a duopoly of Upbit and Bithumb. We analyze the competition-limiting effects and market fairness issues arising from this dominance, with supporting data.

• Part 2: The One-Exchange–One-Bank Practice and Barriers to Entry – We analyze the exclusive real-name account partnerships between exchanges and banks. We explore how this real-name account linkage has acted as a barrier to entry for new players and how it has entrenched the positions of incumbents.

• Part 3: The Pitfalls of the Exchange-as-Everything Model: From Listing to Custody – Domestic exchanges perform multiple critical functions in one place: listing review, asset custody, price formation, and trading support. We examine the conflicts of interest and competitive distortions that can arise from this model, and compare it with the structural separation in traditional financial markets.

• Part 4: Information Asymmetry and Fairness in Investor Protection – We discuss how information asymmetry and lack of transparency around coins disadvantage investors, and what fairness issues arise in current investor protection policies. Through case studies we look at insufficient disclosure, suspected unfair trading, and information gaps in the wake of hacks and other incidents.

• Part 5: Limits of the Korean Market from a Global Competitiveness Perspective – We analyze the structural limits of Korea’s virtual asset market by comparing it to global markets. Topics include how a closed, KRW-centric ecosystem affects global competitiveness, and how local peculiarities such as the “kimchi premium” reveal both the uniqueness and the constraints of the Korean market.

• Part 6: Innovation and Regulatory Reform for a Fairer Market – Building on the preceding analysis, we propose directions for competition-driven innovation and policy reform. We present concrete ideas for improving the real-name account regime, enhancing listing transparency, and strengthening market surveillance, and explore a roadmap toward a fairer market environment.