A 0.04% offer with a costly condition
Bithumb advertised a trading fee of 0.04%, but customers who did not separately register a coupon could face a standard rate of up to 0.25%, or 6.25 times the advertised rate. The difference is now at the center of a Korea Fair Trade Commission examination and a parliamentary debate about whether misleading advertising can remain profitable even when companies face sanctions.
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Figures disclosed at a parliamentary audit showed that the cryptocurrency exchange recorded about 1,332 trillion won in transaction value and 629.83 billion won in fee revenue between February 2024 and February 2025. Applying the advertised rate to that entire trading value would produce 532.8 billion won, approximately 97 billion won less than the reported revenue.
A separate case involving marriage matchmaking company Duo added another concern: repeated advertising violations. The commission imposed a 345 million won surcharge and corrective orders after finding problems with claims about membership, external audits and professional managers. Duo had already been sanctioned over advertising in 2014.
Kim Hyun-jung, a Democratic Party lawmaker on the National Assembly's Political Affairs Committee, challenged whether the timing and size of penalties provide enough deterrence. The two cases involve different services and different stages of enforcement. Bithumb remains under examination, while Duo has received a sanction. Together, they put attention on disclosure, evidence and the cost of repeated violations.
What Bithumb customers had to do
The advertised 0.04% fee was conditional. Customers had to register a separate coupon themselves before receiving that rate. Without registration, the standard fee could reach 0.25%. The commission is examining whether Bithumb adequately disclosed this requirement under the Act on Fair Labeling and Advertising.
That distinction matters because a price can be available without applying automatically. A customer attracted by the advertised rate could still pay more if the step needed to activate it was not sufficiently clear. The question under examination concerns the disclosure of that condition, rather than simply whether a 0.04% rate existed.
For illustration, on a transaction worth 1 million won, a fee of 0.04% would equal 400 won. A fee of 0.25% would equal 2,500 won, a difference of 2,100 won. These calculations show the effect of the two rates; they do not establish what any particular customer paid.
The standard rate was described as reaching up to 0.25%, so it would be inaccurate to assume that every customer without a coupon paid that maximum. The number of customers who registered coupons, the number who did not, and the distribution of rates actually charged have not been established in the figures disclosed at the audit.
What the 97 billion won gap shows
The revenue comparison provides a useful benchmark. Multiplying 1,332 trillion won by 0.04% produces 532.8 billion won. Subtracting that amount from the reported 629.83 billion won in fee revenue gives 97.03 billion won, rounded in the parliamentary account to about 97 billion won.
Reported revenue was therefore approximately 18.2% above the amount that a uniform 0.04% rate would have generated. Dividing reported revenue by reported transaction value also produces an implied average fee rate of about 0.0473%, assuming both figures cover the same transactions and use compatible accounting definitions.
That implied average is much closer to 0.04% than to the maximum standard rate of 0.25%. It illustrates why the maximum price difference and the aggregate revenue difference must be kept separate. One describes what an individual transaction could cost at the stated rates; the other describes revenue across the entire reported trading volume.
The 97 billion won gap is not an established measure of unlawful gains or customer losses. Such a conclusion would require more information about applicable rates, coupon use, disclosures and the basis on which fees were counted. The arithmetic supports scrutiny, but it does not substitute for a finding by the commission.
Two submissions give different revenue totals
A second issue concerns Bithumb's submissions to parliament. The exchange reportedly gave Kim's office fee revenue of about 629.8 billion won, while materials submitted through the commission recorded approximately 612.4 billion won for the same period. The difference is about 17.4 billion won.
The discrepancy affects the size of the comparison with the advertised rate. Using 612.4 billion won instead of 629.83 billion won would leave a gap of 79.6 billion won above the 532.8 billion won benchmark. Both totals exceed that benchmark, but they cannot be treated as interchangeable.
No explanation for the difference has been established in the audit account. It is not clear whether the totals reflect different accounting definitions, exclusions, adjustments or an error. Resolving that question is necessary before either figure can support a precise conclusion about revenue associated with the coupon requirement.
The disclosure issue and the accounting issue are related but distinct. Accurate revenue figures would help assess the scale of the business involved. They would not, by themselves, determine whether customers were adequately informed about how to obtain the advertised fee.
Three Duo claims failed scrutiny
Duo's case concerned claims about the strength and credibility of its matchmaking service. It advertised the industry's largest membership of professionals and prestigious university graduates, described itself as the industry's only company undergoing external audits, and promoted a workforce of 230 professional managers.
The commission found insufficient objective evidence to support the membership claim. This is a narrower finding than establishing which company actually had the largest relevant membership. A claim of industry leadership requires a reliable basis for comparing competitors, and the evidence was found inadequate.
The external audit claim had a different problem: other companies also published external audit results. An external audit involves an independent examination of financial statements. Being audited does not make a company unique when competitors undergo and disclose comparable examinations.
The staffing claim also differed from the work being advertised. Although Duo promoted 230 professional managers, the commission found that 188 employees handled member introductions and meeting arrangements. That is 42 fewer people, or about 18.3% below the advertised figure.
The finding does not establish Duo's total workforce. It concerns the number performing the matchmaking duties relevant to the claim. The distinction matters to prospective customers evaluating how much staff support a service can provide, just as the membership and audit claims can influence perceptions of choice and reliability.
Repeat sanctions and an uncertain chronology
The commission imposed a 345 million won surcharge and corrective orders on Duo in August. The company had previously been sanctioned in 2014 over claims that included an overwhelming number of members and a 63.2% market share. Those earlier claims should not be mistaken for verified measurements of its business.
The repeat action supports Kim's concern that an earlier sanction did not prevent further problematic advertising. It does not establish how much revenue Duo earned from the latest claims, or whether its financial benefit exceeded the surcharge. No such calculation has been disclosed.
The sequence of events also contains an unresolved dating inconsistency:
- 2014: Duo was sanctioned over advertising claims involving membership and a 63.2% market share.
- February 2024 to February 2025: The 13 months covered by the Bithumb transaction and fee revenue figures.
- May 2024: The commission reportedly received the latest Duo case.
- August, with the calendar year unclear: Duo received the latest surcharge and corrective orders.
- The parliamentary audit: Kim challenged the effectiveness of delayed sanctions and the monitoring of repeated violations.
Reports describe the Duo proceedings as lasting about two years and three months, but also give a May 2024 receipt date and differing relative references to the August decision. Those details do not establish a consistent calendar year for the final disposition. The exact chronology needs clarification before the stated duration can be treated as confirmed.
When penalties become a business expense
The audit also identified a monitoring gap: the commission was found to have no separate system for managing and checking businesses with repeated violations. That does not mean earlier enforcement records do not exist. It means there was no dedicated arrangement of the kind raised during the audit.
Kim, the Democratic Party member of the Political Affairs Committee, argued that sanctions must function as punishment rather than an ordinary cost of doing business. He said:
Surcharges must not become a company's operating expense rather than a punishment.
His concern connects two factors: the benefit a company might receive while an advertisement is running, and the penalty imposed afterward. A delayed decision can leave a long interval between attracting customers and facing consequences. A penalty smaller than the benefit could provide weak deterrence, although neither company's net benefit has been established here.
The cases require different next steps. For Bithumb, the unresolved issues include the clarity of the coupon disclosure, reconciliation of revenue submissions and the commission's eventual decision. For Duo, the focus is on the effectiveness of its corrective orders and whether repeated violations receive closer monitoring.
No next hearing date, decision deadline, proposed legislative change or new monitoring timetable has been identified. The record supports a call for more effective enforcement, but it does not show that a new penalty regime has been adopted or that Bithumb has already been found in violation.
Key Points
- Bithumb's advertised 0.04% fee required separate coupon registration; the standard rate could reach 0.25%, or 6.25 times as much.
- Reported fee revenue of 629.83 billion won exceeded the uniform 0.04% benchmark by about 97 billion won, but that gap is not a finding of unlawful gains.
- Two Bithumb submissions differed by approximately 17.4 billion won, with no explanation established.
- Duo received a 345 million won surcharge and corrective orders over membership, audit and staffing claims.
- Duo had also been sanctioned in 2014; reports of the latest case contain an unresolved chronology discrepancy.
- Kim Hyun-jung called for stronger deterrence, while Bithumb's advertising examination remains unresolved.
