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Bank of Korea to Track Cross-Border Crypto Holdings of 1.27 Million Users From December

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The Bank of Korea will begin receiving transaction-by-transaction reports from domestic virtual asset service providers on cryptocurrency transfers to overseas exchanges and personal wallets starting December 3, the date the country’s amended Foreign Exchange Transactions Act takes effect. The central bank is building the reporting framework around its foreign exchange computer network, and alongside the daily transfer logs it is introducing a monthly balance-reporting form designated FX1021 that would cover any exchange user with at least one cross-border transfer on record since July 19, 2024 — a pool of 1,272,878 users across South Korea’s five largest exchanges, according to the Seoul Economic Daily .

The requirements are laid out in a Bank of Korea manual — formally titled the “Manual on Foreign Exchange Computer Network Reporting for Virtual Currency Transfer Operators” — that was delivered to the Digital Asset eXchange Alliance on October 2 and obtained by the office of Rep. Park Soo-young of the People Power Party on October 23. The stated purpose is to let the central bank monitor cross-border movements of funds and crypto assets from a foreign-exchange standpoint, a layer that operates separately from the anti-money-laundering and oversight framework already run by the country’s financial regulators. Bank of Korea officials stressed that the manual is a working draft and that the final scope of reporting will be settled in November after consultations with the Ministry of Economy and Finance and virtual asset operators.

What the New Reporting Regime Requires

Under the manual, operators must report crypto outflows and inflows completed each day to the central bank by 11 a.m. the following business day, beginning December 3. Transactions made on weekends and public holidays may be filed together on the next business day. The daily filing must capture the date and time of each transaction, the type and quantity of virtual currency, the won-converted amount, fees, and information on both senders and recipients.

The monthly FX1021 report sits on top of the daily logs. Providers must file each user’s month-end holdings, their won-converted balances, and the totals for cross-border inflows and outflows during the month, with a deadline of 5:30 p.m. on the 10th day of the following month. The manual explicitly extends balance reporting to dormant accounts, delisted virtual currencies, and assets committed to staking. Two exclusions narrow the field: transactions sent directly between personal wallets without passing through an operator are not reportable, and the central bank’s typical covered case is the everyday one — buying bitcoin on a domestic exchange and moving it to an overseas exchange, or transferring assets from a domestic operator to a personal wallet.

A Baseline That Reaches Back to July 2024

The most consequential design choice is the retroactive baseline. The Bank of Korea’s initial plan would collect monthly balance reports from any user with a single cross-border transfer on record since July 19, 2024 — the date the Virtual Asset User Protection Act took effect — even in months when that user made no new transaction. According to figures from Rep. Park’s office, 1,272,878 users at the country’s five largest exchanges had a cross-border virtual asset transfer record between July 19, 2024 and September 30, 2026.

The arithmetic puts the scale of the obligation in sharper relief than the headline figure alone. The 1,272,878-user pool averages about 254,576 users per exchange, and across the 803-day window from July 19, 2024 to September 30, 2026 the pool grew at roughly 1,585 users per day — a cohort that did not opt into a filing regime but is swept into one by a single past transfer. The central bank, as the designated foreign-exchange information hub, would share the collected data with the National Tax Service, the Korea Customs Service, the Financial Supervisory Service, and the Korea Financial Intelligence Unit for use in investigating illegal foreign-exchange transactions.

Privacy Objections Meet a Central Bank That Is Softening

The lawmaker who surfaced the manual has already objected to its reach. “Looking into all the information of virtual asset users just because they have used an overseas transfer transaction even once is an excessive act of collecting personal information,” Rep. Park Soo-young said, adding that “if personal information, assets, and transaction details are excessively collected in addition to the taxation on virtual assets, the related market could shrink further.”

The Bank of Korea appears to be listening. A senior official acknowledged that “some operators say they face technical difficulties and staffing shortages in applying this retroactively from July 2024,” and said the central bank is “considering easing the rule so that it applies from Dec. 3, the date the law takes effect.” The same official framed the review as open-ended, including a plan to narrow the scope of balance reporting, and raised a separate question about proportionality: “We need to consider whether applying the same reporting standards to large exchanges with active trading and to small operators with almost no trading is equivalent in terms of the effectiveness of monitoring.” The quoted statements were translated from Korean by the Seoul Economic Daily.

Why This Matters Beyond Korea

South Korea is one of the world’s largest retail crypto markets, and the framework adds a foreign-exchange surveillance layer on top of its existing anti-money-laundering controls — a structure that tracks capital leaving the country in the form of digital assets, not just fiat. The contrast with the region’s other cross-border initiatives is striking: while Seoul is tightening the monitoring of crypto moving abroad, its neighbours are building settlement rails in the other direction. Three central banks recently joined a 25-institution push for cross-border stablecoin settlement led by Singapore, while the Bank of Korea is focused on capturing the outflow leg of the same global movement.

The episode also fits a broader pattern of central banks intervening directly in crypto cross-border flows — a dynamic visible in the Bank of Israel’s rejection of a plan to use crypto to circumvent sanctions. That decision showed a central bank drawing a hard line on digital-asset capital flows, just as Seoul is now doing through reporting rather than prohibition.

What remains unsettled is the final scope. If the Bank of Korea holds to the July 2024 baseline, exchanges must identify and value holdings for 1.27 million users; if it shifts the start date to December 3, the burden falls on a smaller, forward-looking cohort. The manual lists December 3 as the effective date, but the bank has said the balance-reporting parameters may still change, with a final format due in November. Until that decision lands, Korean exchanges are preparing for either version of a rule that will reshape how their customers’ crypto is tracked at the border.

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