가상자산사업자의 고객위탁 가상자산 회계처리에 대한 검토

This study examines the practical challenges in accounting for the crypto assets held by a cryptocurrency exchange on behalf of its users and proposes solutions. As crypto asset transactions continue to grow, individual users increasingly engage with cryptocurrency exchanges to trade their crypto assets. Although these assets are inherently the property of the customers, the fact that a cryptocurrency exchange records the transactions on its internal ledger, and that it controls the private keys that are essential for transactions, raises the possibility that these assets could be interpreted as part of the exchange’s own assets. In response to these issues, the Financial Supervisory Service released the “Guidelines for Crypto Asset Accounting Treatment” on December 20, 2023. These guidelines clarify that if a cryptocurrency exchange exercises ‘economic control’ over the crypto assets it holds behalf of its users, the assets should be recognized as a part of the exchange’s assets and liabilities. If no such control exists, the assets should be excluded from the exchange’s financial statements. However, the guidelines do not offer clear, definitive criteria for assessing ‘economic control’ leading to potential reliance on subjective judgment by the cryptocurrency exchange. To address these challenges, this study evaluates existing legal frameworks and cryptocurrency exchanges’ agreements, highlighting the variability in interpretations of the economic control. Based on this analysis, the study presents “whether the cryptocurrency exchange has the right to arbitrarily use the crypto assets it holds on behalf of its users” as the most critical criterion for assessing economic control.