은산분리 규제완화를 위한 소고- 미국과 일본의 은산분리 규제 동향을 중심으로 -

The principle of separating banking and commerce constitutes a core regulatory framework within Korea’s financial industry and has been strictly upheld to this day. However, such rigorous separation does not align with the global standard. Few countries impose strict legal restrictions on the integration of banking and commerce, as seen in Korea. For instance, neither Europe nor Japan imposes specific limitations on the ownership of banks by industrial capital. In the United States, industrial capital ownership is permitted up to 5%, with ownership ranging from 5% to 25% subject to approval by the Federal Reserve System (FRB). Recently, however, digital transformation (DX) has been rapidly expanding across all sectors of society. In particular, the boundaries between financial and non-financial industries are increasingly blurred due to their mutual approach and convergence—a phenomenon often referred to as the “big blur.” Against this backdrop, the principle of separating banking and commerce is being revisited, prompting growing discussions on its reassessment. Korea’s Financial Services Commission has already announced a policy to relax the separation between finance and commerce and is actively engaging in related discussions. This article examines the current role and practical relevance of the Separation of Banking and Commerce regulation in Korea. Specifically, it aims to provide a reference framework for evaluating the validity of Korea’s regulatory system by analyzing the regulatory structures and trends toward relaxation in the United States and Japan. Through this comparative analysis, the article seeks to assess the temporal and international coherence of Korea’s existing regulatory framework and offers several individualized insights.