KR Regulatory Context for Custody Records
How South Korean fiduciary and financial record-keeping expectations shape the structure of offline wallet ceremony documentation.
18 April 2025 · 8 min read
South Korea’s regulatory landscape for digital asset custody continues to evolve. While specific virtual asset service provider licensing under the Virtual Asset User Protection Act applies to exchanges and custodians, family offices and private trustees operate under broader fiduciary and corporate governance expectations that nonetheless demand documented custody practices.
Fiduciary Record-Keeping Expectations
The Commercial Act and trust law principles require trustees to maintain records sufficient to demonstrate faithful execution of their duties. For trustees holding hardware wallets, this translates to documented evidence that access events were authorised, witnessed where required, and consistent with the trust instrument.
Financial Record Retention Periods
Corporate entities subject to the External Audit of Stock Companies Act must retain accounting-related records for prescribed periods, typically five to ten years depending on document type. Ceremony logs that support balance verification or asset transfer decisions may fall within these retention requirements.
Personal Information Considerations
Ceremony logs frequently contain participant names and photographs. Under the Personal Information Protection Act (PIPA), data controllers must specify the purpose of collection, obtain consent for photographs, and define retention periods. Our ceremony packets include a PIPA-compliant consent form for photographic documentation.
What Regulators Look For
In our experience supporting clients through financial examinations, reviewers focus on:
- Chronological completeness — no unexplained gaps between access events
- Authorisation evidence — who approved the access and under what authority
- Independence of witnesses — whether the witness holds a conflicted role
- Consistency with stated policy — whether the ceremony followed the client’s own custody procedures
Practical Recommendation
Maintain ceremony records in a single archival structure with cross-references between events. When policy changes, document the change date and apply the revised procedure to subsequent ceremonies without retroactively altering past logs.
This article is informational and does not constitute legal advice. Consult qualified counsel for guidance specific to your regulatory obligations.