The judgment of the court below is reversed.

Defendants are not guilty.

1. Summary of grounds for appeal;

A. (1) The Defendants’ assertion of misunderstanding of facts or misapprehension of legal principles (1) paid the membership fees to the members who have joined the membership fees and returned the amount equivalent to the existing membership fees, which is a kind of benefit, such as activity expenses, to the members actively participating in the collective activities. Since the Defendants’ act does not constitute an act of receiving the same kind of membership fees from the beginning, it does not constitute an act of receiving the membership fees, since they did not agree to return all or more of the membership fees paid from the beginning.

(2) Unless otherwise, the Defendants registered and operated D (F; hereinafter only referred to as D) as non-profit organizations for the purpose of missionary and welfare activities, and collected membership fees from members who have contributed to the purpose of the above activities, and provided benefits as above in the process of promoting the invitation of members. Therefore, it is reasonable to deem that the Defendants did not have the awareness of illegality and there was considerable reason for such mistake.

B. Even if Defendant A’s conviction on Defendant A’s assertion of unfair sentencing is acknowledged, considering that the above Defendant did not have previous conviction and suffered economic difficulties, the lower court’s punishment (fine 7 million won) is too unreasonable.

2. Summary of the facts charged and the judgment of the court below

A. The summary of the facts charged is the Chairperson of Gwanak-gu in Seoul Special Metropolitan City, and Defendant A is the Secretary General of the above organization, and Party E is the representative director of the above organization.

No one shall make an agreement to pay the total amount of investments or an amount in excess thereof to an unspecified number of unspecified persons in the future without obtaining authorization, permission, registration, reporting, etc. from the competent authority, and receive the investments without any delay.

Nevertheless, the Defendants from April 1, 2010 to the same year.

6. By the end of the month.