The judgment of the court below is reversed.

Of the facts charged in the instant case, 1 to 721 set forth in the attached list of crimes.

1. Summary of grounds for appeal;

A. misunderstanding of facts and misunderstanding of legal principles are independent corporations that have separate entities from Defendant B Co., Ltd. (hereinafter “B”), and it is impossible for the Defendants to report deposit transactions between Hong Kong and Hong Kong to the heads of designated foreign exchange banks.

In addition, since Defendant A was a director of the Hong Kong corporations, he cannot be punished as joint penal provisions, since he was involved in the above deposit transactions.

Of the facts charged in the instant case, the part No. 1-721 of the attached Table No. 1-721, among the charges of this case, shall be acquitted as the statute of limitations has lapsed, and thus, the judgment of acquittal shall be rendered. Since the part No. 722-1, 452, which is the basis for the amount subject to punishment, does not constitute an unreported capital transaction exceeding one billion won or five billion

B. The lower court’s sentence of unreasonable sentencing (the Defendant’s each fine of KRW 70 million) is too unreasonable.

2. Judgment on misconception of facts and misapprehension of legal principles

A. Under the summary of the facts charged in the instant case, where a resident intends to engage in foreign currency deposit transactions with a nonresident abroad, he/she shall report to the head of the designated foreign exchange bank. On February 25, 2009, Defendant A deposited USD 45,160.03 with a ship fuel oil brokerage deposit account in the name of Hong Kong FF in the name of E on February 25, 2009, and deposited USD 139,782,271.93 (the total amount of USD 157,68,395,131) over 1,452 times from that time until March 8, 2017, as shown in the list of crimes in the attached Form, without reporting to the head of the designated foreign exchange bank. Defendant B, a representative director, violated the Foreign Exchange Transactions Act with respect to Defendant B’s business.

B. Before the relevant provision was amended by Act No. 9351 of Jan. 30, 2009, Article 18(1) of the Foreign Exchange Transactions Act provides for the obligation to report capital transactions and Article 28(1)4 of the same Act uniformly provides for criminal punishment.