Emerging Risks: Virtual Assets, Fintech, and New Payment Methods
This domain tests how Korean AML rules apply to virtual assets, fintech onboarding, and new payment methods. The exam expects risk-based adaptation, not a separate rulebook.
Core rules
- Virtual asset service providers must register or report to KoFIU, meet AML obligations, and use real-name verified accounts where required.
- Korea's Travel Rule requires VASPs to collect and transmit originator and beneficiary information for virtual asset transfers of KRW 1 million or more.
- VASPs must screen wallet addresses and counterparties, monitor for structuring and mixers, and file STRs when suspicion arises.
- Fintech and non-face-to-face onboarding require robust electronic identity verification, liveness checks, and fraud controls; convenience does not lower CDD standards.
- New payment methods such as prepaid wallets, mobile remittances, and cross-border fintech products need a product risk assessment before launch.
Worked example
A registered VASP processes a KRW 1.5 million transfer to an unhosted wallet. Because the amount exceeds the KRW 1 million Travel Rule threshold, the VASP must obtain and verify originator and beneficiary information, screen the wallet, assess the customer's profile, and consider an STR if the wallet is linked to high-risk activity.
Traps
Do not apply the KRW 10 million cash threshold to virtual asset transfers. Do not assume virtual assets are anonymous or outside AML law. Do not launch a new payment product without assessing channel, customer, and cross-border risk.