All appeals by the Defendants are dismissed.

1. Summary of grounds for appeal;

A. In fact, the Defendants, misunderstanding of the legal principles, did not engage in foreign exchange brokerage or investment brokerage, since the Defendants agreed to distribute the profits at a certain rate between the investors in the event that the profits accrued from the investors’ Mady transactions and the profits accrued therefrom.

Nevertheless, the lower court rendered a judgment on the premise that the Defendants’ act constitutes foreign exchange brokerage or investment brokerage, either by misapprehending the facts or by misapprehending the legal doctrine.

B. The punishment sentenced by the lower court to Defendant A, B, and C (Defendant A, B: fine of KRW 10 million, and fine of KRW 5 million) is too unreasonable.

2. Determination

A. According to the evidence duly adopted and examined by the lower court, the lower court determined that: (a) based on the Defendants’ misunderstanding of the facts and misapprehension of the legal doctrine, the lower court acknowledged the fact that the Defendants solicited the investors to engage in the trade of FX M, and educated the HTS program use method; and (b) obtained the identification card, passbook, e-mail address, e-mail password, etc. necessary for the FX M& M trading from the investors to open an overseas account; and (c) in so doing, the Defendants recommended the investors to arrange for the sale and purchase of foreign derivatives; and (d) mediated the FX M& M transaction that constitutes foreign exchange transactions.

It is reasonable to see that the Defendants engaged in the investment brokerage business and foreign exchange brokerage business without obtaining authorization under the Financial Investment Services and Capital Markets Act (hereinafter “Capital Market Act”) and the Foreign Exchange Transaction Act.

may be deemed to have been

The decision was determined.

2) In light of the above judgment of the court below in light of the following circumstances acknowledged by the evidence duly admitted and investigated by the court below, the judgment of the court below is just and acceptable, and it is erroneous or erroneous.