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A Cambodia-headquartered financial group recently cut off from the U.S. financial system is suspected of having operated in South Korea, raising fresh questions about cross-border crypto and currency flows tied to the group. According to the Dong-A Ilbo, which cited data from the Korea Customs Service (KCS), Huione Group—now sanctioned by the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN)—appears to have run a currency exchange in Seoul from 2018 to July 2024. The outlet reported that a banner on the premises displayed a logo identical to Huione’s, prompting suspicions about its ownership and control.Photo by Aleksandar Pasaric on PexelsTies to North Korean hackersThe exchange reported conducting roughly $20,000 in annual currency conversions during that period, excluding cryptocurrency transactions. The timeline overlaps with a period in which Huione Group reportedly received $150,000 in cryptocurrency from the North Korean hacking group Lazarus.  Connections also extend to Cambodia. Panda Bank—a local lender that shares a building with Huione subsidiaries—supports USDT transactions originating from South Korea. Panda Bank director He Yanming is listed as the owner of Huione Crypto, a virtual asset service provider (VASP), suggesting potential links between operations in Seoul and Phnom Penh. These developments come against the backdrop of a U.S. investigation disclosed in May, in which FinCEN said Huione’s business networks, including payments arm Huione Pay, collectively laundered at least $4 billion in illicit proceeds between August 2021 and January 2025. Crypto used in $2.6B illegal conversionsMeanwhile, recent KCS data also shows a rise in illegal currency conversions involving cryptocurrency by foreign nationals. The Korea Economic Daily reported conversions totaling 432 billion won ($302 million) in 2021, climbing to 836 billion won ($584.5 million) in 2023 and 956 billion won ($668.4 million) last year. Over the past eight years, the total amount involved in such cases reached 3.7 trillion won ($2.59 billion) across 28 instances. By value, Chinese nationals accounted for 84.1% of the total, followed by Australians (11.1%), Vietnamese (3.2%), and Russians (1.6%). The growing prevalence of cryptocurrency in illicit activity parallels a broader surge in crypto investment within the country. Many South Koreans have turned to digital assets, often with home ownership as a long-term goal. Trading on local exchanges, Bloomberg reported, is heavily skewed toward more volatile altcoins, which make up more than 80% of total volume.  That stands in contrast to global markets, where investors largely focus on Bitcoin and Ethereum, which together make up more than half of overall trading. The momentum in local crypto investment intensified after Donald Trump’s U.S. presidential victory, with crypto trading in Korea reaching $27 billion in December 2024, about 80% of turnover on the KOSPI stock index. The investigation underscores the growing challenge for regulators in tracking and containing cross-border financial networks that rely on cryptocurrency and informal money transfers. As crypto adoption deepens in South Korea and scrutiny widens abroad, authorities find themselves navigating an increasingly intricate intersection of financial opportunity, enforcement, and risk. 

Strengthened KYC Spurs More Suspicious Transaction Reports from Korean Crypto ExchangesIn South Korea this year, there has been a significant surge in the number of suspicious transaction reports (STRs) related to cryptocurrencies, according to local news agency Yonhap.This increase is primarily attributed to cryptocurrency exchanges fortifying their Know Your Customer (KYC) procedures. This proactive response follows the controversy surrounding lawmaker Kim Nam-kuk’s significant virtual asset holdings, which were unveiled in May. His scandal came to light when a substantial amount of WEMIX tokens, valued in billions of Korean won, were transferred from the Bithumb exchange to the Upbit exchange. Upbit, deeming it a suspicious transaction, promptly reported the matter to the Financial Intelligence Unit (FIU) of the Financial Services Commission (FSC).Photo by ron dyar on UnsplashGrowing number of suspicious transaction reportsAs the scandal continued to gain traction, the political realm reached a consensus to conduct investigations into the cryptocurrency holdings of all lawmakers. Additionally, the National Human Rights Commission of Korea initiated the tracking of all lawmakers’ cryptocurrency holdings last month, a process set to span 90 days.Data received by lawmaker Yoon Young-deok on October 30 from the FIU reveals that the number of STRs originating from virtual asset service providers (VASPs) has reached 11,646 in the first nine months of this year. This figure has already exceeded last year’s total of 10,797 STRs.Under the current Act on Reporting and Using Specified Financial Transaction Information, commonly referred to as the Financial Transaction Reporting Act, VASPs are mandated to report to the FIU if they have reasonable grounds to suspect that a customer’s financial transactions are connected to illicit property, money laundering, or terrorist financing. The Act has been in full effect since October 2021.In 2021, a total of 199 reports were submitted under this Act. The number of reports surged to over 10,000 the following year, and in the current year, it continues to grow at an even faster rate. The FIU reviews and analyzes these STRs in accordance with Article 10 of the Financial Transaction Reporting Act. It forwards the relevant information to law enforcement agencies only when it is deemed necessary for the investigation of a specific criminal case.Enhanced but varied approaches by exchangesCrypto exchanges have bolstered their customer verification requirements, especially for customers deemed to have a high risk of involvement in money laundering, in accordance with the Financial Transaction Reporting Act. This entails the need for additional scrutiny of the source of funds and the purpose behind transactions. Notably, if customer verification appears suspicious, exchanges are mandated to confirm the authenticity of the information using reliable documents.However, it’s important to note that the enforcement decree accompanying this Act grants exchanges the flexibility to verify documents based on their own business guidelines. This autonomy has been provided to assist exchanges in effectively mitigating money laundering risks by taking into account their individual business rights and characteristics.For instance, Upbit, South Korea’s largest cryptocurrency exchange, has implemented a fraud detection system (FDS) powered by artificial intelligence to continuously monitor and identify fraudulent transactions. This initiative has earned Upbit recognition from the FIU as an outstanding organization for reporting suspicious transactions during the first half of this year.On the contrary, Bithumb has devised and applies internal guidelines dedicated to anti-money laundering (AML) measures. The exchange has instituted a streamlined customer verification process for customers who are assessed as having a low likelihood of being engaged in money laundering activities. However, this simplified process is not extended to individuals from countries that have not adopted the recommendations of the Financial Action Task Force (FATF).Korbit monitors information related to customer verification through a dedicated department. It declines transactions for customers who have not undergone sufficient verification and validation procedures.Coinone’s AML department examines customer transactions comprehensively. It maintains ongoing reviews of customer information, business operations, risk assessments, and the source of funds. If any of these aspects are found to be suspicious or inadequate, the AML department proceeds with additional customer verification, including the disclosure of the source of funds.Some raise concerns about the inconsistency in customer verification standards for AML and STRs across different exchanges. When one exchange flags a transaction as suspicious, another might see it as routine. Such discrepancies highlight the need for uniform guidelines. Addressing this, the Digital Asset eXchange Association (DAXA), consisting of Korea’s five leading currency exchanges — Upbit, Bithumb, Coinone, Korbit, and Gopax — has set up an AML division to devise standardized rules for STRs.

Temasek Cuts Pay Following FTX AutopsySingaporean state-owned investment firm, Temasek Holdings, has announced a reduction in compensation for executives responsible for the company’s investment in the now-defunct cryptocurrency exchange FTX. Temasek, once the second-largest outside investor in FTX, faced scrutiny after the collapse of the exchange.Photo by Emilio Takas on UnsplashNo misconduct findingOn May 29, Temasek released a statement confirming the completion of its internal review of the $275 million investment loss incurred from FTX. The review determined that there was “no misconduct” within the company. However, both the investment team and senior management took “collective accountability” and experienced a reduction in their compensation.While acknowledging the inherent risks associated with any investment, Temasek emphasized the importance of continuing to invest in new sectors and emerging technologies to understand their potential impact on the business and financial models of existing portfolios. They recognized the need to adapt to an ever-changing world and explore avenues that could drive future value.It’s worth noting that the $275 million loss from the FTX investment constituted only 0.09% of Temasek’s portfolio value, which stood at over $293 billion at the time of the collapse.Temasek maintained that it conducted extensive due diligence before investing in FTX, emphasizing its commitment to a thorough review process. Chairman Lim Boon Heng stated in a May 29 interview with Bloomberg that there was fraudulent conduct intentionally hidden from investors, including Temasek. The negative outcome of the investment has been disappointing for the company and has had a significant impact on its reputation.Reputational damageSingapore Deputy Prime Minister Lawrence Wong echoed similar sentiments, highlighting the financial loss and reputational damage caused by the FTX collapse during a parliamentary meeting in November 2022.During the due diligence process, Temasek reviewed FTX’s financial statements, assessed regulatory risks related to financial service providers in the cryptocurrency market, and sought legal advice. The company also engaged with individuals who had firsthand knowledge of FTX, including employees, investors, and industry participants.In recent news, Temasek addressed and dismissed rumors about a $10 million investment in Array, a developer of algorithmic currency systems based on smart contracts and artificial intelligence. The company clarified that such reports were incorrect, refuting the circulating news articles and tweets.Temasek’s internal review process is certainly a move towards transparency and accountability. It indicates a willingness towards addressing the matter. That said, there are FTX creditor groups who fervently disagree with Temasek’s analysis.Class action lawsuitEarlier this year a number of FTX creditors filed a class action lawsuit against a number of venture capital (VC) firms, including Temasek. The FTX customers maintain that Temasek and others played a role in a conspiracy to defraud them. Venture capital firms have countered with the view that they themselves were victims as a consequence of the FTX collapse, suffering multi-million dollar losses.The fact remains that VCs get much further involved than merely handing over a check. They get involved with marketing, operations, and many other facets of the businesses of their portfolio companies. Meanwhile, other creditors suggest that Temasek has a responsibility to do right by the 1.4 million FTX creditors (a disproportionate number of them being Singapore-based) and to invest in a restructured FTX business, an option that represents the best opportunity for FTX customers to recover their funds.Temasek may have reached certain conclusions by way of their internal report on the matter but this is not likely to be the final analysis relative to its involvement in the fall of FTX.