China vs South Korea
Crypto regulation comparison
China
South Korea
China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.
South Korea is one of the world's largest crypto markets. The Virtual Asset Users Protection Act (VAUPA), effective July 2024, provides comprehensive investor protection including requirements for exchanges to hold user assets in cold storage and carry insurance. All VASPs must register with FIU and comply with strict AML rules under the Specific Financial Information Act. A 20% crypto gains tax (above KRW 2.5 million exemption, raised from the original 250K KRW threshold) has been deferred multiple times and is now scheduled for January 2027.
Key Points
- All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
- Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
- Financial institutions and payment companies prohibited from facilitating crypto services
- China actively developing and piloting the digital yuan (e-CNY) CBDC
- Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks
Key Points
- Virtual Asset Users Protection Act (VAUPA) effective July 2024 — major investor protection law
- VASPs must register with FIU and partner with real-name verified bank accounts
- 20% national tax (22% effective incl. 2% local income surtax) above KRW 2.5M annual exemption (deferred to January 2027)
- Exchanges must hold 80%+ of user assets in cold wallets and carry insurance/reserves
- Only won-denominated trading pairs allowed on major exchanges (Upbit, Bithumb, Coinone, Korbit)