Although the defendant is engaged in foreign exchange business such as payment, collection, receipt, etc., he did not register with the Minister of Strategy and Finance after being equipped with sufficient capital facilities and human resources.

Upon receipt of a request from the persons of Indonesian nationality residing in the Republic of Korea to send salaries, etc. to their families in Indonesia, the Defendant received the Korean won currency deposit from the Defendant’s account opened in the Republic of Korea (foreign exchange bank B and Nonghyup C) using the Defendant’s name (foreign exchange bank B and Nonghyup C) and intended to perform foreign exchange work without actual remittance process, such as transferring the amount from 20,000 to 25,000 won per 20,000 won per 1,000 won to the Defendant’s wife, using the Defendant’s account in his name (E), BNI bank account (F), and BRI bank account (F).

On January 22, 201, the Defendant received a request from G, who is a citizen of Indonesia, to send 15,000 won to his family in Korean won, and received 315,000 won from the foreign exchange bank account (B) in the name of the Defendant, who is the refund account, and then transferred 2,662,00 U.S. from G to the Indones bank account known by G, from that time until July 19, 2012, the Defendant paid 723,672,370 won in total from the requester and paid 5,000 won after deducting the fee to the account designated by the clients.

The Defendant, around October 26, 201, received a request from H, who is a national of Indonesia, to send them to his/her family in Indonesia, equivalent to the won currency, and is thus returned to him/her.