South Korea vs San Marino
Crypto regulation comparison
South Korea
San Marino
Legal
Legal
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.
San Marino has developed a regulatory framework for blockchain entities. The country has issued licenses for blockchain-based businesses.
Tax Type
Varies
Tax Type
Unclear
Tax Rate
20%
Tax Rate
N/A
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
FSC (Financial Services Commission), FSS, FIU (Korea Financial Intelligence Unit)
Regulator
Central Bank of San Marino, AIF (Financial Information Agency)
Stablecoin Rules
Under development; stablecoins subject to VASP rules
Stablecoin Rules
No specific stablecoin regulation
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)
Key Points
- Delegated Decree on blockchain technology entities issued
- Licenses issued for blockchain-based businesses
- AIF provides regulatory oversight
- Small jurisdiction working to attract blockchain companies
- Developing comprehensive digital asset regulation