The judgment of the court below is reversed.

A defendant shall be punished by imprisonment for not more than ten months.

Of the facts charged in the instant case, the access media.

1. Summary of grounds for appeal;

A. Fact-misunderstanding and legal doctrine 1) The Defendant’s act does not constitute “transfer of access media” under Article 6(3)1 of the Electronic Financial Transactions Act, inasmuch as the Defendant’s act does not constitute “transfer of access media” under Article 6(3)1 of the Electronic Financial Transactions Act, inasmuch as a loan is executed after lending the passbook and the OTP card to one person for a fixed period of up to six months.

2) A person who pays D for the transfer of an access medium is not the Defendant, but the Defendant merely delivers D money received from the “E” to D. Thus, this does not constitute “the act of delivering and distributing the access medium while receiving the price” under Article 6(3)2 of the Electronic Financial Transactions Act.

3) Nevertheless, the lower court erred by misapprehending the facts or by misapprehending the legal doctrine that found the Defendant guilty of each of the charges, thereby adversely affecting the conclusion of the judgment

B. The punishment sentenced by the lower court (one year and six months of imprisonment) is too unreasonable.

2. Determination on the misapprehension of facts and misapprehension of legal principles

A. The following circumstances are acknowledged based on the evidence duly adopted and examined by the court below and the court below as to the transfer of access media. In other words, the head of the Tong, etc., which the defendant, was newly established in the name of corporation I established by the defendant to deliver to the "E" rather than the previous use, the defendant did not impose restrictions on the use or period of the above head of the Tong, etc., and the defendant was thought to return the above access media to the "E" six months after lending the above access media to the "E".

However, even if following the Defendant’s statement made by the investigative agency, the Defendant was aware of the “E” through the advertisement of lending the leaflet and did not know the personal information including the real name of the “E”, and did not take any special measures to receive the above passbook, etc. differently, and the Defendant did not.