A Seoul Administrative Court has annulled the Financial Intelligence Unit’s (FIU) three-month partial business suspension of Dunamu, the operator of the Upbit cryptocurrency exchange, local media report.
The court sided with Dunamu in its challenge to the FIU sanction tied to alleged anti-money-laundering (AML) deficiencies. Judges found that while rules governing transactions above 1 million won (about $675) were clear, guidance for smaller transfers lacked sufficient specificity, weakening the legal basis for enforcement in this case.
The decision constrains the FIU’s ability to impose major AML penalties on exchanges where compliance obligations are not explicitly defined in practice. The ruling also resolves a dispute that began after the FIU issued the sanction in February 2025; the penalty had been stayed by the court while Dunamu’s lawsuit was pending.
In its reasoning, the court rejected the FIU’s claim that Dunamu failed to take adequate measures, noting the regulator had not provided precise instructions on required actions. The court said Dunamu had implemented internal measures and that, even if those steps appear insufficient with hindsight, it was difficult to establish intent or gross negligence—undermining the justification for the suspension.
The FIU had imposed the three-month partial suspension on Feb. 25, 2025, restricting newly registered Upbit users from transferring digital assets. The penalty followed an on-site inspection that the FIU said found Dunamu had facilitated transactions with unregistered overseas virtual asset service providers (VASPs) and fell short on customer due diligence. The FIU reported identifying more than 600,000 suspected Know Your Customer (KYC) violations in its review of Upbit’s exchange license.
Dunamu filed suit and sought an injunction on Feb. 28, 2025. On March 27, 2025, the court granted an injunction permitting Upbit to continue onboarding new users while the legal challenge proceeded. The latest ruling effectively cancels the FIU’s suspension, pending any further appeals or regulatory action.