Skip to main content

4 posts tagged with "crypto market"

Cryptocurrency market analysis

View all tags

Inside the $1.5 Billion Bybit Heist: How North Korea Pulled Off History's Largest Crypto Theft

· 10 min read
Dora Noda
Software Engineer

On February 21, 2025, North Korean hackers stole $1.5 billion in cryptocurrency from Dubai-based exchange Bybit in approximately 30 minutes. It wasn't just the largest crypto heist in history—if Bybit were a bank, it would rank as the largest bank robbery ever recorded by Guinness World Records.

The attack didn't exploit a smart contract bug or brute-force a private key. Instead, hackers compromised a single developer's laptop at a third-party wallet provider, waited patiently for weeks, and struck when Bybit employees were approving what looked like a routine internal transfer. By the time anyone realized something was wrong, 500,000 ETH had vanished into a labyrinth of wallets controlled by North Korea's Lazarus Group.

This is the story of how it happened, why it matters, and what it reveals about the state of crypto security in 2025.

The Attack: A Masterclass in Patience and Precision

The Bybit hack wasn't a smash-and-grab. It was a surgical operation that unfolded over weeks.

Phase 1: Compromising the Developer

On February 4, 2025, a developer at Safe{Wallet}—a widely-used multi-signature wallet platform that Bybit relied on for securing large transfers—downloaded what appeared to be a legitimate Docker project called "MC-Based-Stock-Invest-Simulator-main." The file likely arrived via a social engineering attack, possibly disguised as a job opportunity or investment tool.

The malicious Docker container immediately established a connection to an attacker-controlled server. From there, the hackers extracted AWS session tokens from the developer's workstation—the temporary credentials that grant access to Safe{Wallet}'s cloud infrastructure.

With these tokens, the attackers bypassed multi-factor authentication entirely. They now had the keys to Safe{Wallet}'s kingdom.

Phase 2: The Dormant Code

Rather than act immediately, the attackers injected subtle JavaScript code into Safe{Wallet}'s web interface. This code was specifically designed for Bybit—it would lie dormant until detecting that a Bybit employee had opened their Safe account and was about to authorize a transaction.

The sophistication here is remarkable. The entire Safe{Wallet} application functioned normally for every other user. Only Bybit was targeted.

Phase 3: The Heist

On February 21, 2025, Bybit employees initiated what should have been a routine transfer from a cold wallet (secure, offline storage) to a warm wallet (for active trading). This required multiple signatures from authorized personnel—a standard security practice called multisig.

When the signers opened Safe{Wallet} to approve the transaction, the interface displayed what appeared to be the correct destination address. But the malicious code had already swapped in a different command. The employees unknowingly approved a transaction that drained Bybit's entire cold wallet.

Within minutes, 500,000 ETH—worth approximately $1.5 billion—flowed to addresses controlled by the attackers.

The Technical Exploit: Delegatecall

The key vulnerability was Ethereum's delegatecall function, which allows a smart contract to execute another contract's code within its own storage context. The attackers tricked Bybit's signers into changing their wallet's contract logic to a malicious version, effectively granting full control to the hackers.

This wasn't a bug in Ethereum or in Safe{Wallet}'s core protocol. It was an attack on the human layer—the moment when trusted employees verify and approve transactions.

North Korea's Lazarus Group: The World's Most Profitable Hackers

Within 24 hours of the attack, blockchain investigator ZachXBT submitted evidence to Arkham Intelligence definitively connecting the hack to North Korea's Lazarus Group. The FBI confirmed this attribution on February 26, 2025.

Lazarus Group—also known as TraderTraitor and APT38—operates under North Korea's Reconnaissance General Bureau. It's not a criminal gang seeking profit for personal enrichment. It's a state-sponsored operation whose proceeds fund North Korea's nuclear weapons and ballistic missile programs.

The numbers are staggering:

  • 2025 alone: North Korean hackers stole $2.02 billion in cryptocurrency
  • Bybit's share: $1.5 billion (74% of North Korea's 2025 haul from a single attack)
  • Since 2017: North Korea has stolen over $6.75 billion in crypto assets
  • 2025 vs 2024: 51% year-over-year increase in stolen value

North Korea accounted for 59% of all cryptocurrency stolen globally in 2025 and 76% of all exchange compromises. No other threat actor comes close.

The Industrialization of Crypto Theft

What makes North Korea different isn't just the scale—it's the sophistication of their operation.

Social Engineering Over Technical Exploits

The majority of 2025's major hacks were perpetrated through social engineering rather than technical vulnerabilities. This represents a fundamental shift. Hackers are no longer primarily hunting for smart contract bugs or cryptographic weaknesses. They're targeting people.

Lazarus Group operatives have embedded themselves as IT workers inside crypto companies. They've impersonated executives. They've sent job offers containing malware to developers. The Bybit attack began with a developer downloading a fake stock trading simulator—a classic social engineering vector.

The Chinese Laundromat

Stealing crypto is only half the challenge. Converting it to usable funds without getting caught is equally complex.

Rather than cash out directly, North Korea has outsourced money laundering to what investigators call the "Chinese Laundromat"—a sprawling network of underground bankers, OTC brokers, and trade-based laundering intermediaries. These actors wash stolen assets across chains, jurisdictions, and payment rails.

By March 20, 2025—less than a month after the Bybit hack—CEO Ben Zhou reported that hackers had already converted 86.29% of the stolen ETH to Bitcoin through multiple intermediary wallets, decentralized exchanges, and cross-chain bridges. The 45-day laundering cycle following major thefts has become a predictable pattern.

Despite these efforts, Zhou noted that 88.87% of the stolen assets remained traceable. But "traceable" doesn't mean "recoverable." The funds flow through jurisdictions with no cooperative relationship with U.S. or international law enforcement.

Bybit's Response: Crisis Management Under Fire

Within 30 minutes of discovering the breach, CEO Ben Zhou took command and began providing real-time updates on X (formerly Twitter). His message was blunt: "Bybit is Solvent even if this hack loss is not recovered, all of clients assets are 1 to 1 backed, we can cover the loss."

The exchange processed over 350,000 withdrawal requests within 12 hours—a signal to users that despite the catastrophic loss, operations would continue normally.

Emergency Funding

Within 72 hours, Bybit had replenished its reserves by securing 447,000 ETH through emergency funding from partners including Galaxy Digital, FalconX, and Wintermute. Bitget loaned 40,000 ETH to ensure withdrawals continued uninterrupted—a loan Bybit repaid within three days.

Cybersecurity firm Hacken conducted a proof-of-reserves audit confirming that Bybit's major assets were backed by more than 100% collateral. The transparency was unprecedented for a crisis of this magnitude.

The Bounty Program

Zhou declared "war against Lazarus" and launched a global bounty program offering up to 10% rewards for information leading to frozen assets. By year's end, Bybit had paid $2.18 million in USDT to contributors who helped trace or recover funds.

The Market's Verdict

By the end of 2025, Bybit had crossed 80 million users globally, recorded $7.1 billion in daily trading volume, and ranked 5th among cryptocurrency spot exchanges. The crisis response had become a case study in how to survive a catastrophic hack.

2025: The Year Crypto Theft Hit $3.4 Billion

The Bybit hack dominated headlines, but it was part of a broader pattern. Total cryptocurrency theft reached $3.4 billion in 2025—a new record and the third consecutive year of increases.

Key statistics:

  • 2023: $2 billion stolen
  • 2024: $2.2 billion stolen
  • 2025: $3.4 billion stolen

North Korea's share grew from roughly half to nearly 60% of all crypto theft. The DPRK achieved larger thefts with fewer incidents, demonstrating increasing efficiency and sophistication.

Lessons Learned: Where Security Failed

The Bybit hack exposed critical vulnerabilities that extend far beyond a single exchange.

Third-Party Risk Is Existential

Bybit didn't have a security failure. Safe{Wallet} did. But Bybit suffered the consequences.

The crypto industry has built complex dependency chains where exchanges rely on wallet providers, wallet providers rely on cloud infrastructure, and cloud infrastructure relies on individual developer workstations. A compromise anywhere in this chain can cascade catastrophically.

Cold Storage Isn't Enough

The industry has long treated cold wallets as the gold standard of security. But Bybit's funds were in cold storage when they were stolen. The vulnerability was in the process of moving them—the human approval step that multisig was designed to protect.

When transfers become routine, signers develop a false sense of security, treating approvals as formalities rather than critical security decisions. The Bybit attack exploited exactly this behavioral pattern.

The UI Is a Single Point of Failure

Multisig security assumes that signers can verify what they're approving. But if the interface displaying transaction details is compromised, verification becomes meaningless. The attackers showed signers one thing while executing another.

Pre-signing simulations—allowing employees to preview the actual destination of a transaction before approval—could have prevented this attack. So could delays for large withdrawals, giving time for additional review.

Social Engineering Beats Technical Security

You can have the most sophisticated cryptographic security in the world, and a single employee downloading the wrong file can bypass all of it. The weak point in cryptocurrency security is increasingly human, not technical.

Regulatory and Industry Implications

The Bybit hack is already reshaping the regulatory landscape.

Expect mandatory requirements for:

  • Hardware security modules (HSMs) for key management
  • Real-time transaction monitoring and anomaly detection
  • Regular third-party security audits
  • Enhanced AML frameworks and transaction delays for large transfers

Security and compliance are becoming thresholds for market access. Projects that cannot demonstrate strong key management, permission design, and credible security frameworks will find themselves cut off from banking partners and institutional users.

What This Means for the Industry

The Bybit hack reveals an uncomfortable truth: crypto's security model is only as strong as its weakest operational link.

The industry has invested heavily in cryptographic security—zero-knowledge proofs, threshold signatures, secure enclaves. But the most sophisticated cryptography is irrelevant if an attacker can trick a human into approving a malicious transaction.

For exchanges, the message is clear: security innovation must extend beyond technology to encompass operational processes, third-party risk management, and continuous employee training. Regular audits, collaborative threat intelligence sharing, and incident response planning are no longer optional.

For users, the lesson is equally stark: even the largest exchanges with the most sophisticated security can be compromised. Self-custody, hardware wallets, and distributed asset storage remain the safest long-term strategies—even if they're less convenient.

Conclusion

North Korea's Lazarus Group has industrialized cryptocurrency theft. They've stolen over $6.75 billion since 2017, with 2025 marking their most successful year yet. The Bybit hack alone—$1.5 billion in a single operation—demonstrates capabilities that would make any intelligence agency envious.

The crypto industry is in an arms race with state-sponsored hackers who have unlimited patience, sophisticated technical capabilities, and no fear of consequences. The Bybit attack succeeded not because of any novel exploit but because attackers understood that humans, not code, are the weakest link.

Until the industry treats operational security with the same rigor it applies to cryptographic security, these attacks will continue. The question isn't whether another billion-dollar hack will happen—it's when, and whether the target will respond as effectively as Bybit did.


This article is for educational purposes only and should not be considered financial advice. Always conduct your own research and prioritize security when interacting with cryptocurrency exchanges and wallets.

Hong Kong vs Mainland China: A Tale of Two Crypto Policies Under One Country

· 9 min read
Dora Noda
Software Engineer

Fifty kilometers apart, two regulatory systems govern crypto with such stark opposition that they might as well exist in different universes. Mainland China bans all cryptocurrency trading, mining, and as of November 2025, even stablecoins—while Hong Kong actively courts the industry with an expanding licensing framework, spot ETFs, and ambitions to become Asia's preeminent digital asset hub. The "One Country, Two Systems" principle has never been more dramatically illustrated than in how these jurisdictions approach Web3.

For builders, investors, and institutions navigating the Greater China market, understanding this regulatory divergence isn't just academic—it's existential. The difference between operating 50 kilometers north or south of the border can mean the difference between building a licensed, regulated business and facing criminal prosecution.


The Mainland Position: Total Prohibition Reinforced

China's stance on cryptocurrency has hardened into one of the world's most comprehensive bans. What began as restrictions in 2013 has evolved into blanket prohibition covering virtually every aspect of the crypto ecosystem.

The 2025 Crackdown Intensifies

On November 28, 2025, Chinese financial and judicial authorities convened to reinforce their position: all crypto-related business activities are illegal in mainland China. The enforcement decree, effective June 1, 2025, established clear penalties including transaction suspension and asset seizure.

The most significant development was the explicit ban on stablecoins—including those pegged to major global or domestic fiat currencies. This closed what many considered the last gray area in Chinese crypto regulation.

Key prohibitions now include:

  • Mining, trading, and even holding crypto assets
  • Issuing, exchanging, or raising funds using tokens or stablecoins
  • RWA (Real-World Asset) tokenization activities
  • Domestic staff participation in offshore tokenization services

The enforcement framework is formidable. The People's Bank of China (PBOC) leads regulatory efforts, directing financial institutions to block crypto-related transactions. The Cyberspace Administration of China (CAC) polices the internet, shutting down websites, apps, and social media accounts promoting crypto. Technical infrastructure enabling tokenization faces active monitoring and disruption.

The Blockchain Exception

Yet China's policy isn't anti-blockchain—it's anti-crypto. Officials announced a roadmap for national blockchain infrastructure targeting 400 billion yuan ($54.5 billion) in annual investments over five years. The distinction is clear: permissioned, state-controlled blockchain good; permissionless, token-based systems bad.

The digital yuan (e-CNY) continues receiving state backing and active development, representing China's vision for controlled digital currency innovation. By separating blockchain infrastructure from tradeable tokens, China maintains technological competitiveness while preserving capital controls and monetary sovereignty.

Underground Reality

Despite comprehensive prohibition, enforcement faces practical limits. China is estimated to have approximately 59 million crypto users as of 2025, operating through P2P platforms and VPN-based wallet access. The gap between policy and reality creates ongoing challenges for regulators and opportunities—albeit illegal ones—for determined participants.


Hong Kong's Contrasting Vision: Regulated Embrace

While the mainland prohibits, Hong Kong regulates. The Special Administrative Region has constructed an increasingly sophisticated framework designed to attract legitimate crypto businesses while maintaining robust investor protections.

The VASP Licensing Framework

Since June 2023, all Virtual Asset Service Providers (VASPs) serving Hong Kong investors must hold an SFC-issued license. The requirements are stringent:

RequirementDetails
Asset CustodyAt least 98% of client assets in cold storage
Fund SegregationComplete separation of client and company assets
KYC/AMLMandatory checks and suspicious transaction reporting
Travel RuleCompliance for transfers exceeding HKD 8,000
ManagementFit and proper personnel with cybersecurity safeguards

Licensed exchanges include HashKey Exchange, OSL Digital Securities, and HKVAX—platforms that can legally serve both retail and institutional investors.

The Stablecoin Ordinance

Effective August 1, 2025, Hong Kong introduced dedicated licensing for fiat-referenced stablecoin issuers. Requirements include:

  • Minimum paid-up share capital of HKD 25 million
  • Full reserve backing with high-quality, liquid assets
  • Regulatory approval from the Hong Kong Monetary Authority

This positions Hong Kong to host compliant stablecoin issuers at a time when mainland China has explicitly banned all stablecoin activities.

Spot ETF Success

Hong Kong made history on April 30, 2024, launching Asia's first spot Bitcoin and Ethereum ETFs. Six virtual asset ETFs began trading on the Hong Kong Stock Exchange, issued by Harvest Global Investments, HashKey Capital/Bosera Asset Management, and China Asset Management's Hong Kong unit.

By late December 2024, Hong Kong crypto ETF assets reached $467 million—modest compared to U.S. ETF assets exceeding $122 billion, but significant for the region. The spot Bitcoin ETFs accumulated 4,560 BTC ($444.6 million), while Ether funds held 16,280 ETH ($59.6 million).

In 2025, the expansion continued with Pando Finance launching the city's first Bitcoin ETF of the year and Hong Kong approving its first Solana ETF—a product category not yet available in the United States.

The ASPIRe Roadmap

The SFC's "ASPIRe" roadmap articulates Hong Kong's ambitions to become a global digital asset hub. On June 26, 2025, the Financial Services and Treasury Bureau (FSTB) issued its second policy statement advancing this strategic vision.

Key November 2025 developments included:

  • Expansion of products and services for licensed VATPs
  • Integration of order books with global affiliate platforms
  • Enabling shared global liquidity for Hong Kong exchanges

2026 Legislative Plans

Hong Kong plans to introduce legislative proposals for virtual asset dealers and custodians in 2026. The new licensing framework under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance will create requirements modeled on existing Type 1 securities rules—meaning crypto dealers will follow the same strict standards as traditional finance.

Consultations on regulating virtual asset advisory and management services closed in January 2026, with implementation expected later in the year.


Side-by-Side Comparison

The regulatory contrast couldn't be sharper:

DimensionMainland ChinaHong Kong
Crypto TradingBanned (criminal penalties)Legal (licensed exchanges)
MiningBannedNot explicitly prohibited
StablecoinsExplicitly banned (Nov 2025)Regulated (HKMA licensing)
ICOs/Token IssuanceBannedRegulated case-by-case
Retail AccessProhibitedAllowed on licensed platforms
Spot ETFsNot availableApproved (BTC, ETH, SOL)
RWA TokenizationBannedUnder development
Regulatory ApproachProhibition + enforcementRegulation + innovation
CBDCe-CNY (state-controlled)HKD stablecoins (private)
Estimated Users~59 million (underground)Growing (licensed)

Strategic Implications

For Exchanges and Trading Platforms

Mainland operations are impossible. Hong Kong offers a legitimate path to serving Chinese-speaking markets, but strict licensing requirements demand significant investment. The passporting potential—reaching global liquidity through Hong Kong licenses—makes compliance economically attractive for serious operators.

For Stablecoin Issuers

The contrast creates clear routing: Hong Kong welcomes compliant issuers with substantial reserve requirements; mainland China criminalizes the entire category. For projects targeting Greater China, Hong Kong licensing is the only legitimate option.

For Institutional Investors

Hong Kong's ETF framework and expanding product offerings create regulated access points. The combination of spot ETFs, licensed custody, and traditional finance integration makes Hong Kong increasingly attractive for institutional allocation to digital assets.

For Web3 Builders

The arbitrage opportunity is geographic. Hong Kong permits innovation within regulatory bounds; mainland China permits blockchain innovation only without tokens. Projects requiring token economics must locate in Hong Kong; pure blockchain infrastructure may find mainland resources and market access valuable.

For the Industry

Hong Kong's regulatory development represents a proof-of-concept for comprehensive crypto regulation within the Chinese legal tradition. Success could influence other Asian jurisdictions and potentially—though this remains speculative—inform eventual mainland policy evolution.


The Equilibrium Question

How long can such divergent policies coexist? The "One Country, Two Systems" framework permits significant regulatory divergence, but mainland authorities have historically shown willingness to intervene when Hong Kong policies conflict with national interests.

Several factors suggest the current equilibrium may be stable:

Arguments for stability:

  • Hong Kong's role as international financial center requires regulatory compatibility with global markets
  • Digital asset regulation doesn't threaten core mainland concerns (territorial integrity, political control)
  • Hong Kong serves as a controlled experiment and potential release valve
  • Capital controls remain enforceable through mainland banking systems

Arguments for potential convergence:

  • Mainland enforcement increasingly targets offshore service providers with domestic staff
  • Success in Hong Kong could attract mainland capital through gray channels
  • Political pressure could align Hong Kong more closely with mainland positions

The November 2025 mainland statement extending enforcement to "domestic staff of offshore service providers" suggests authorities are aware of and actively countering regulatory arbitrage.


Conclusion: Navigating the Divide

The Hong Kong-Mainland divide offers a stark lesson in regulatory philosophy. Mainland China prioritizes capital controls, financial stability, and monetary sovereignty—choosing prohibition as the simplest enforcement mechanism. Hong Kong prioritizes international competitiveness and financial innovation—choosing regulation as the path to managed participation.

For market participants, the practical implications are clear:

  1. Mainland China: Zero legal tolerance for crypto activity. The 59 million estimated users operate entirely outside legal protection.

  2. Hong Kong: Expanding opportunities within a demanding regulatory framework. Licensed operations gain access to both local and global markets.

  3. The border matters: 50 kilometers creates entirely different legal realities. Corporate structuring, staff location, and operational jurisdiction require careful consideration.

As Hong Kong continues building its regulatory infrastructure through 2026 and beyond, it offers an increasingly compelling case study in how jurisdictions can embrace digital assets while maintaining robust investor protections. Whether this experiment influences broader regional or even mainland policy remains to be seen—but for now, the tale of two crypto policies continues to unfold just 50 kilometers apart.


References

Korea's 15-20% Exchange Ownership Caps: A Regulatory Earthquake Reshaping Asia's Crypto Landscape

· 10 min read
Dora Noda
Software Engineer

South Korea just dropped a regulatory bombshell that could fundamentally restructure the world's second-largest crypto trading market. On December 30, 2025, the Financial Services Commission (FSC) unveiled plans to cap major shareholder ownership in cryptocurrency exchanges at 15-20%—a move that would force the founders of Upbit, Bithumb, Coinone, and Korbit to sell billions of dollars in equity.

The implications extend far beyond Korea's borders. With Korean won already rivaling the US dollar as the world's most-traded fiat currency for crypto, and $110 billion already fleeing to foreign exchanges in 2025 alone, the question isn't just how Korean exchanges will adapt—it's whether Korea will retain its position as Asia's retail crypto powerhouse, or cede ground to Singapore, Hong Kong, and Dubai.


The Numbers Behind the Bombshell

The FSC's proposal targets exchanges classified as "core infrastructure"—defined as platforms with over 11 million users. This captures Korea's Big Four: Upbit, Bithumb, Coinone, and Korbit.

Here's what the current ownership structure looks like versus what compliance would require:

ExchangeMajor ShareholderCurrent StakeRequired Reduction
Upbit (Dunamu)Song Chi-hyung25%~5-10%
CoinoneCha Myung-hoon54%~34-39%
BithumbHolding Company73%~53-58%
KorbitNXC + SK Square~92% combined~72-77%
GOPAXBinance67.45%~47-52%

The math is brutal. Coinone's founder would need to sell more than half his stake. Bithumb's holding company would need to divest over 70% of its position. Binance's control of GOPAX becomes untenable.

The FSC frames this as transforming founder-controlled private enterprises into quasi-public infrastructure—similar to Alternative Trading Systems (ATS) under Korea's Capital Markets Act. The proposal also signals a shift from the current registration system to a full licensing regime, with regulators conducting fitness reviews of major shareholders.


A Market Too Big to Ignore—and Too Concentrated to Ignore

Korea's crypto market is a paradox: massive in scale, dangerously concentrated in structure.

The numbers tell the story:

  • $663 billion in crypto trading volume in 2025
  • 16 million+ users (32% of the nation's population)
  • Korean won ranks as the #2 fiat currency for global crypto trading, sometimes surpassing USD
  • Daily trades frequently exceeded $12 billion

But within this market, Upbit dominates with near-monopoly force. In H1 2025, Upbit controlled 71.6% of all trading volume—833 trillion won ($642 billion). Bithumb captured 25.8% with 300 trillion won. The remaining players—Coinone, Korbit, GOPAX—collectively account for less than 5%.

The FSC's concern isn't abstract. When a single platform handles 70%+ of a nation's crypto trading, operational failures, security breaches, or governance scandals don't just affect investors—they become systemic risks to financial stability.

Recent data reinforces this worry. During Bitcoin's December 2024 rally to all-time highs, Upbit's market share spiked from 56.5% to 78.2% in a single month as retail traders consolidated on the dominant platform. That's the kind of concentration that keeps regulators awake at night.


The Capital Flight Already Happening

Korea's regulatory posture has already triggered a capital exodus that dwarfs the proposed ownership restructuring in significance.

In the first nine months of 2025 alone, Korean investors transferred 160 trillion won ($110 billion) to foreign exchanges—triple the outflow from all of 2023.

Why? Domestic exchanges are limited to spot trading. No futures. No perpetuals. No leverage. Korean traders who want derivatives—and the volume data suggests millions of them do—have no choice but to go offshore.

The beneficiaries are clear:

  • Binance: ₩2.73 trillion in fee income from Korean users
  • Bybit: ₩1.12 trillion
  • OKX: ₩580 billion

Combined, these three platforms extracted ₩4.77 trillion from Korean users in 2025—2.7x the combined revenue of Upbit and Bithumb. The regulatory framework designed to protect Korean investors is instead pushing them to less-regulated venues while transferring billions in economic activity abroad.

The FSC's ownership caps could accelerate this trend. If forced divestments create uncertainty about exchange stability, or if major shareholders exit the market entirely, retail confidence could collapse—pushing even more volume offshore.


The Asia Crypto Hub Competition

Korea's regulatory gamble plays out against a fierce regional competition for crypto industry dominance. Singapore, Hong Kong, and Dubai are all vying to become the definitive Asian crypto hub—and each has different strategic advantages.

Hong Kong: The Aggressive Comeback

Hong Kong has emerged from China's shadow with surprising momentum. By June 2025, the city had granted 11 Virtual Asset Trading Platform (VATP) licenses, with more pending. The Stablecoin Ordinance, implemented August 2025, created Asia's first comprehensive licensing regime for stablecoin issuers—with the first licenses expected in early 2026.

The numbers are compelling: Hong Kong led Eastern Asia with 85.6% growth in crypto activity in 2024, according to Chainalysis. The city is explicitly positioning itself to attract crypto talent and firms from competitors like the US, Singapore, and Dubai.

Singapore: The Cautious Incumbent

Singapore's approach is the opposite of Korea's heavy-handed intervention. Under the Payment Services Act and Digital Payment Token regime, the Monetary Authority of Singapore emphasizes stability, compliance, and long-term risk management.

The tradeoff is speed. While Singapore's reputation for regulatory clarity and institutional trust is unmatched, its cautious stance means slower adoption. The June 2025 Digital Token Service Provider framework set strict requirements that restrict many overseas-focused issuers.

For Korean exchanges facing ownership caps, Singapore offers a potential safe harbor—but only if they can meet MAS's exacting standards.

Dubai: The Wild Card

Dubai's Virtual Asset Regulatory Authority (VARA) has positioned the emirate as the "anything goes" alternative to more restrictive Asian jurisdictions. With no personal income tax, a dedicated crypto regulatory framework, and aggressive courting of exchanges and projects, Dubai has attracted major players looking to escape regulatory pressure elsewhere.

If Korea's ownership caps trigger a wave of exchange migrations, Dubai is well-positioned to capture the flow.


What Happens to the Exchanges?

The FSC's proposal creates three possible paths for Korea's major exchanges:

Scenario 1: Forced Divestment and Restructuring

If the regulations pass as proposed, major shareholders face a stark choice: sell down stakes to comply, or fight the law in court. Given the political momentum behind the proposal, compliance seems more likely.

The question is who buys. Institutional investors? Foreign strategic acquirers? A distributed pool of retail shareholders? Each buyer profile creates different governance dynamics and operational priorities.

For Bithumb, already pursuing a 2026 NASDAQ IPO, forced divestment might actually accelerate the public listing timeline. Going public naturally diversifies ownership while providing liquidity for existing shareholders.

For Upbit, a potential merger with internet giant Naver could provide cover for ownership restructuring while creating a formidable combined entity.

Scenario 2: Regulatory Rollback

The crypto industry isn't accepting the proposal quietly. Exchange operators have responded with sharp criticism, arguing that forced ownership dispersion would:

  • Eliminate accountable controlling shareholders, creating ambiguity about responsibility when problems arise
  • Infringe on property rights without clear constitutional justification
  • Weaken domestic exchanges against international competitors
  • Trigger investor flight as uncertainty increases

Industry groups are pushing for behavioral regulations and voting rights restrictions as alternatives to forced divestment. Given the proposal's still-preliminary status—the FSC has emphasized that specific thresholds remain under discussion—there's room for negotiation.

Scenario 3: Market Consolidation

If smaller exchanges can't afford the compliance costs and governance restructuring required under the new regime, the Big Four could become the Big Two—or even the Big One.

Upbit's dominant market position means it has the resources to navigate regulatory complexity. Smaller players like Coinone, Korbit, and GOPAX may find themselves squeezed between ownership restructuring costs and inability to compete with Upbit's scale.

The irony: a regulation designed to disperse ownership concentration could inadvertently increase market concentration as weaker players exit.


The Stablecoin Deadlock

Complicating everything is Korea's ongoing battle over stablecoin regulation. The Digital Asset Basic Act, originally expected in late 2025, has stalled over a fundamental disagreement:

  • The Bank of Korea insists only banks with 51% ownership should issue stablecoins
  • The FSC warns this approach could hinder innovation and cede the market to foreign issuers

This deadlock has pushed the bill's passage to January 2026 at earliest, with full implementation unlikely before 2027. Meanwhile, Korean traders who want stablecoin exposure are—once again—forced offshore.

The pattern is clear: Korean regulators are caught between protecting domestic financial stability and losing market share to more permissive jurisdictions. Every restriction that "protects" Korean investors also pushes them toward foreign platforms.


What This Means for the Region

Korea's ownership cap proposal has implications beyond its borders:

For foreign exchanges: Korea represents one of the most lucrative retail markets globally. If domestic regulatory pressure increases, offshore platforms stand to capture even more of that volume. The $110 billion already flowing to foreign exchanges in 2025 could be just the beginning.

For competing Asian hubs: Korea's regulatory uncertainty creates opportunity. Hong Kong's licensing momentum, Singapore's institutional credibility, and Dubai's permissive stance all become more attractive as Korean exchanges face forced restructuring.

For global crypto markets: Korean retail traders are a major source of volume, particularly for altcoins. Any disruption to Korean trading activity—whether from exchange instability, regulatory uncertainty, or capital flight—reverberates through global crypto markets.


The Road Ahead

The FSC's ownership cap proposal remains preliminary, with implementation unlikely before late 2026 at earliest. But the direction is clear: Korea is moving toward treating crypto exchanges as quasi-public utilities requiring distributed ownership and enhanced regulatory oversight.

For the exchanges, the next 12-18 months will require navigating unprecedented uncertainty while maintaining operational stability. For Korean retail traders—16 million of them—the question is whether domestic platforms can remain competitive, or whether the future of Korean crypto trading lies increasingly offshore.

The Asia crypto hub race continues, and Korea just made its position significantly more complicated.


References

What Are Memecoins? A Crisp, Builder-Friendly Primer (2025)

· 10 min read
Dora Noda
Software Engineer

TL;DR

Memecoins are crypto tokens born from internet culture, jokes, and viral moments. Their value is driven by attention, community coordination, and speed, not fundamentals. The category began with Dogecoin in 2013 and has since exploded with tokens like SHIB, PEPE, and a massive wave of assets on Solana and Base. This sector now represents tens of billions in market value and can significantly impact network fees and on-chain volumes. However, most memecoins lack intrinsic utility; they are extremely volatile, high-turnover assets. The risks of "rug pulls" and flawed presales are exceptionally high. If you engage, use a strict checklist to evaluate liquidity, supply, ownership controls, distribution, and contract security.

The 10-Second Definition

A memecoin is a cryptocurrency inspired by an internet meme, a cultural inside joke, or a viral social event. Unlike traditional crypto projects, it is typically community-driven and thrives on social media momentum rather than underlying cash flows or protocol utility. The concept began with Dogecoin, which was launched in 2013 as a lighthearted parody of Bitcoin. Since then, waves of similar tokens have emerged, riding new trends and narratives across different blockchains.

How Big Is This, Really?

Don't let the humorous origins fool you—the memecoin sector is a significant force in the crypto market. On any given day, the aggregate market capitalization of memecoins can reach tens of billions of dollars. During peak bull cycles, this category has accounted for a material share of the entire non-BTC/ETH crypto economy. This scale is easily visible on data aggregators like CoinGecko and in the dedicated "meme" categories featured on major crypto exchanges.

Where Do Memecoins Live?

While memecoins can exist on any smart contract platform, a few ecosystems have become dominant hubs.

  • Ethereum: As the original smart contract chain, Ethereum hosts many iconic memecoins, from $DOGE-adjacent ERC-20s to tokens like $PEPE. During periods of intense speculative frenzy, the trading activity from these tokens has been known to cause significant spikes in network gas fees, even boosting validator revenue.
  • Solana: In 2024 and 2025, Solana became the ground zero for memecoin creation and trading. A Cambrian explosion of new tokens pushed the network to record-breaking fee generation and on-chain volume, birthing viral hits like $BONK and $WIF.
  • Base: Coinbase's Layer 2 network has cultivated its own vibrant meme sub-culture, with a growing list of tokens and dedicated community tracking on platforms like CoinGecko.

How a Memecoin Is Born (2025 Edition)

The technical barrier to launching a memecoin has dropped to near zero. Today, two paths are most common:

1. Classic DEX Launch (EVM or Solana)

In this model, a creator mints a supply of tokens, creates a liquidity pool (LP) on a decentralized exchange (like Uniswap or Raydium) by pairing the tokens with a base asset (like $ETH, $SOL, or $USDC), and then markets the token with a story or meme. The primary risks here hinge on who controls the token contract (e.g., can they mint more?) and the LP tokens (e.g., can they pull the liquidity?).

2. Bonding-Curve “Factory” (e.g., pump.fun on Solana)

This model, which surged in popularity on Solana, standardizes and automates the launch process. Anyone can instantly launch a token with a fixed supply (often one billion) onto a linear bonding curve. The price is automatically quoted based on how much has been bought. Once the token reaches a certain market cap threshold, it "graduates" to a major DEX like Raydium, where the liquidity is automatically created and locked. This innovation dramatically lowered the technical barrier, shaping the culture and accelerating the pace of launches.

Why builders care: These new launchpads compress what used to be days of work into minutes. The result is massive, unpredictable traffic spikes that hammer RPC nodes, clog mempools, and challenge indexers. At their peak, these memecoin launches on Solana generated transaction volumes that matched or exceeded all previous network records.

Where "Value" Comes From

Memecoin value is a function of social dynamics, not financial modeling. It typically derives from three sources:

  • Attention Gravity: Memes, celebrity endorsements, or viral news stories act as powerful magnets for attention and, therefore, liquidity. In 2024–2025, tokens themed around celebrities and political figures saw massive, albeit often short-lived, trading flows, particularly on Solana DEXs.
  • Coordination Games: A strong community can rally around a narrative, a piece of art, or a collective stunt. This shared belief can create powerful reflexive price movements, where buying begets more attention, which begets more buying.
  • Occasional Utility Add-Ons: Some successful memecoin projects attempt to "bolt on" utility after gaining traction, introducing swaps, Layer 2 chains, NFT collections, or games. However, the vast majority remain purely speculative, trade-only assets.

The Risks You Can’t Ignore

The memecoin space is rife with dangers. Understanding them is non-negotiable.

Contract and Control Risk

  • Mint/Freeze Authority: Can the original creator mint an infinite supply of new tokens, diluting holders to zero? Can they freeze transfers, trapping your funds?
  • Ownership/Upgrade Rights: A contract with "renounced" ownership, where the admin keys are burned, reduces this risk but doesn't eliminate it entirely. Proxies or other hidden functions can still pose a threat.

Liquidity Risk

  • Locked Liquidity: Is the initial liquidity pool locked in a smart contract for a period of time? If not, the creator can perform a "rug pull" by removing all the valuable assets from the pool, leaving the token worthless. Thin liquidity also means high slippage on trades.

Presales and Soft Rugs

  • Even without a malicious contract, many projects fail. Teams can abandon a project after raising funds in a presale, or insiders can slowly dump their large allocations on the market. The infamous $SLERF launch on Solana showed how even an accidental mistake (like burning the LP tokens) can vaporize millions while paradoxically creating a volatile trading environment.

Market and Operational Risk

  • Extreme Volatility: Prices can swing 90%+ in either direction within minutes. Furthermore, the network effects of a frenzy can be costly. During $PEPE's initial surge, Ethereum gas fees skyrocketed, making transactions prohibitively expensive for late buyers.
  • Rug pulls, pump-and-dumps, phishing links disguised as airdrops, and fake celebrity endorsements are everywhere. Study how common scams work to protect yourself. This content does not constitute legal or investment advice.

A 5-Minute Memecoin Checklist (DYOR in Practice)

Before interacting with any memecoin, run through this basic due diligence checklist:

  1. Supply Math: What is the total supply vs. the circulating supply? How much is allocated to the LP, the team, or a treasury? Are there any vesting schedules?
  2. LP Health: Is the liquidity pool locked? For how long? What percentage of the total supply is in the LP? Use a blockchain explorer to verify these details on-chain.
  3. Admin Powers: Can the contract owner mint new tokens, pause trading, blacklist wallets, or change transaction taxes? Has ownership been renounced?
  4. Distribution: Check the holder distribution. Is the supply concentrated in a few wallets? Look for signs of bot clusters or insider wallets that received large, early allocations.
  5. Contract Provenance: Is the source code verified on-chain? Does it use a standard, well-understood template, or is it full of custom, unaudited code? Beware of honeypot patterns designed to trap funds.
  6. Liquidity Venues: Where does it trade? Is it still on a bonding curve, or has it graduated to a major DEX or CEX? Check the slippage for the trade size you are considering.
  7. Narrative Durability: Does the meme have genuine cultural resonance, or is it a fleeting joke destined to be forgotten by next week?

What Memecoins Do to Blockchains (and Infra)

Memecoin frenzies are a powerful stress test for blockchain infrastructure.

  • Fee and Throughput Spikes: Sudden, intense demand for blockspace stresses RPC gateways, indexers, and validator nodes. In March 2024, Solana recorded its highest-ever daily fees and billions in on-chain volume, driven almost entirely by a memecoin surge. Infrastructure teams must plan capacity for these events.
  • Liquidity Migration: Capital rapidly concentrates around a few hot DEXs and launchpads, reshaping Miner Extractable Value (MEV) and order-flow patterns on the network.
  • User Onboarding: For better or worse, memecoin waves often serve as the first point of contact for new crypto users, who may later explore other dApps in the ecosystem.

Canonical Examples (For Context, Not Endorsement)

  • $DOGE: The original (2013). A proof-of-work currency that still trades primarily on its brand recognition and cultural significance.
  • $SHIB: An Ethereum ERC-20 token that evolved from a simple meme into a large, community-driven ecosystem with its own swap and L2.
  • $PEPE: A 2023 phenomenon on Ethereum whose explosive popularity significantly impacted on-chain economics for validators and users.
  • BONK & WIF (Solana): Emblematic of the 2024-2025 Solana wave. Their rapid rise and subsequent listings on major exchanges catalyzed massive activity on the network.

For Builders and Teams

If you must launch, default to fairness and safety:

  • Provide clear and honest disclosures. No hidden mints or team allocations.
  • Lock a meaningful portion of the liquidity pool and publish proof of the lock.
  • Avoid presales unless you have the operational security to administer them safely.
  • Plan your infrastructure. Prepare for bot activity, rate-limit abuse, and have a clear communication plan for volatile periods.

If you integrate memecoins into your dApp, sandbox flows and protect users:

  • Display prominent warnings about contract risks and thin liquidity.
  • Clearly show slippage and price impact estimates before a user confirms a trade.
  • Expose key metadata—like supply figures and admin rights—directly in your UI.

For Traders

  • Treat position sizing like leverage: use only a small amount of capital you are fully prepared to lose.
  • Plan your entry and exit points before you trade. Do not let emotion drive your decisions.
  • Automate your security hygiene. Use hardware wallets, regularly review token approvals, use allow-listed RPCs, and practice identifying phishing attempts.
  • Be extremely cautious of spikes caused by celebrity or political news. These are often highly volatile and revert quickly.

Quick Glossary

  • Bonding Curve: An automated mathematical formula that sets a token's price as a function of its purchased supply. Common in pump.fun launches.
  • LP Lock: A smart contract that time-locks liquidity pool tokens, preventing the project creator from removing liquidity and "rugging" the project.
  • Renounced Ownership: The act of surrendering the admin keys to a smart contract, which reduces (but doesn't entirely eliminate) the risk of malicious changes.
  • Graduation: The process of a token moving from an initial bonding curve launchpad to a public DEX with a permanent, locked liquidity pool.

Sources & Further Reading

  • Binance Academy: "What Are Meme Coins?" and "Rug pull" definitions.
  • Wikipedia & Binance Academy: DOGE and SHIB origins.
  • CoinGecko: Live memecoin market statistics by sector.
  • CoinDesk: Reporting on Solana fee spikes, PEPE’s impact on Ethereum, and the SLERF case study.
  • Decrypt & Wikipedia: Explanations of pump.fun mechanics and its cultural impact.
  • Investopedia: Overview of common crypto scams and defenses.

Disclosure: This post is for educational purposes and is not investment advice. Crypto assets are extremely volatile. Always verify data on-chain and from multiple sources before making any decisions.