South Korea vs United States

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.

The United States has the world's most complex crypto regulatory landscape, with overlapping federal and state jurisdictions. The SEC regulates crypto securities and has pursued enforcement actions against exchanges and token issuers. The CFTC oversees crypto derivatives and considers Bitcoin a commodity. FinCEN applies BSA requirements to crypto exchanges as money service businesses. The IRS taxes crypto as property: short-term gains at income tax rates (10-37%), long-term gains at 0-20%. New 1099-DA broker reporting rules take effect from 2025. Multiple states have their own requirements, with New York's BitLicense being the most stringent.