A proposed share swap between Upbit parent Dunamu and NAVER Pay, a payment affiliate of South Korean internet giant NAVER, may face regulatory complications. Materials disclosed by the Legislative Research Office of South Korea's National Assembly indicate the deal could be subject both to minimum ownership requirements for holding-company subsidiaries under the Fair Trade Act and to limits on the maximum stake held by a major shareholder of a virtual asset exchange (a crypto trading platform). NAVER Pay does not currently appear to be a holding company. If it later becomes one and classifies the exchange as a subsidiary, the two opposing ownership standards could apply simultaneously, requiring changes to the governance structure. The Fair Trade Act sets minimum holdings of 30% in listed subsidiaries and 50% in unlisted subsidiaries for holding companies, while venture capital holding companies face a 20% threshold.