Regulation Is Also Accumulation

We Fall Behind Where We Believe We Excel

Korea believes it excels at digital finance. The entire population sends money via mobile, and its simple payment penetration rate is among the world's highest. But when you shift your gaze to the virtual asset market, the scene changes. By trading volume, Korea has always been among the global top ranks, but the rules underpinning those transactions have mostly come from outside. As of 2026, the institutional form of the won-denominated stablecoin remains undetermined, and the industry law has been dragging on with only second-stage legislation announced.

During the same period, different things happened outside. The EU activated MiCA, launching a unified system requiring stablecoin issuers to maintain capital, segregate reserves, and submit to continuous supervision. The U.S. defined payment stablecoins at the federal level through the GENIUS Act. Hong Kong created a stablecoin ordinance and issuance licenses, and the Monetary Authority of Singapore introduced a single-currency stablecoin framework early on. The UAE aligned itself with dirham-pegged tokens and VARA licenses.

What's interesting is that each rationale differs. Europe brandished consumer protection and monetary sovereignty, the U.S. the digital extension of dollar hegemony, Hong Kong a bypass route for mainland capital, and Singapore and the UAE financial hub attraction. The starting points are all different, yet the destination is the same. Register issuers, bind reserves one-to-one, and guarantee redemption. Five jurisdictions converged on nearly the same single sentence for different reasons.

Fast Catch-Up Cannot Write This Sentence

Here lies a familiar misconception Korea falls into. The idea that since that sentence has been agreed upon, we just need to translate and import it as is. The logic of catch-up. The belief that quickly copying someone else's solved answer will narrow the gap. This model, which worked in semiconductors and displays, is assumed to work for institutions as well.

It doesn't work. Regulatory standards are not finished products but the product of negotiation. Behind one line of MiCA lies the memory of financial collapse Europe experienced after the Cyprus crisis and the joint defensive battle central banks waged that stranded Libra. Behind one line of the GENIUS Act lies the U.S. Treasury's long-term calculation to redeploy the dollar as digital infrastructure. Even if the sentences look the same, the countries that created those sentences also possess the capacity to operate, revise, and export them.

A country that only translates has the sentence but not the sentence's muscle. In the next round, when, for instance, tokenized deposits or cross-border payment standards come to the negotiating table, the country that copied must copy again. Each time one beat late, each time shouldering someone else's premises.

Here comes a counterargument. Since regulation is better the more conservative it is, isn't it rational to follow verified overseas standards even if late? It's half right. In financial stability, prudence is a virtue. But following late and being unable to create rules are different problems. Cautiously copying is still copying, and a copying country has no voice in reflecting its own market's unique risks—such as currency risks of won-denominated assets or the characteristics of domestic exchange structures—into standards.

Institutions Are Built Only Through Trial and Error

Institutions for frontier technology are not perfected in one go. They accumulate through trial and error. The Monetary Authority of Singapore could quickly present its single-currency stablecoin framework because it had previously run fintech regulatory sandboxes for years, accumulating hundreds of failures and recoveries as data. The EU's MiCA underwent years of public consultation, draft discards, and rewrites starting in 2018. A system where failures are documented and those documents become input for the next rules. That is institutional accumulation.

Korea has a weak accumulation structure. There is a financial regulatory sandbox, but it's closer to a temporary exemption, and when the exemption ends, experience disperses. Records of experiments one ministry attempted do not transfer as assets to the next ministry. When personnel change, context resets. Short-term performance orientation makes only success cases reported, and failures are hidden. Hidden failures are not learned, and unlearned failures repeat in the same form.

The real weapon of advanced jurisdictions is not the rules themselves but the memory of the institutions that create them. The UK's FCA, Singapore's MAS, and Europe's ESMA have accumulated decades of supervisory judgments and their outcomes internally. When new technology emerges, they retrieve past cases to compare and adjust. This thickness of memory is negotiating power for standards.

What Korea Must Accumulate

So what should be accumulated? First, perpetuation of supervisory data. Making transaction, incident, and sanction data that began accumulating through virtual asset service provider registration and the Travel Rule into institutional assets that accumulate beyond administrations and personnel. Next, an experimental structure where failures are not discarded. A circuit that leaves the success or failure of sandbox graduate companies and their reasons as public data and reintroduces them as grounds for next rule design. Last, long-term postings of specialized personnel to enter standard negotiations. The financial hub infrastructure gathered at Busan BIFC is closer to hardware. What's truly lacking is the continuity of people—the same faces going to international standard meetings for decades to build trust.

The delay in won stablecoin discussions is not due to lack of technology. It's because experience in designing for ourselves—on the conditions of our market—how to bind issuers, where to place reserves, and who guarantees redemption is thin. The process itself of trying that design once, getting it wrong, and fixing it becomes negotiating power for the next round.

Not Answers, But Questions

In the era of catch-up, countries that found answers quickly won. The single sentence five jurisdictions agreed on already looks like the answer. So we want to copy it. But that sentence is an answer that came from someone else's question, not an answer from our question.

The next sentence has not yet been written. Rules for tokenized deposits, cross-border payments, and programmable money are now being drafted in someone's laboratory. The country that sets the premises of those drafts will hold the next standard. The question Korea must ask is this: Do we quickly solve problems others posed, or do we create the problems themselves? In the frontier era, the country that creates questions first wins.