Four PillarsFour PillarsAsia Digital Asset Policy Center

Letters

Prepare for vaults, the on-chain infrastructure of asset management

Curated vaults put human managers back into on-chain yield. Rules should address their risks and the securities question they raise.

To
Financial Services Commission; Financial Supervisory Service
From
Bok Jin-sol, Head of Research, Four Pillars
Date
2026.09.10
Occasion
Digital Asset Finance Innovation seminar, Post Tower, Seoul, 10 Sep 2026 (hosted by Reps. Min Byung-deok and Ahn Do-geol, organised by KORFIN)

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Bok Jin-sol of Four Pillars presenting on on-chain vaults
Photo: eToday

What we ask

  1. Recognise on-chain vaults as an emerging asset management channel in the second phase of digital asset legislation.
  2. Set disclosure and risk standards for smart contract, oracle, collateral and liquidity risk.
  3. Clarify when a curated vault, where a manager decides the strategy, becomes a security or a collective investment scheme.

An on-chain vault is a smart contract that takes deposits and puts them to work. Users deposit stablecoins, bitcoin or ether and receive vault share tokens; the assets are allocated to staking, lending protocols, real-world assets or decentralised exchanges to earn a return.

The fastest-growing form is the curated vault. A professional curator decides the strategy and an allocator moves the funds, while users receive the yield.

On-chain does not mean risk-free

Smart contract bugs, oracle failures, and collateral and liquidity risk all remain. Because people actively run the strategy in a curated vault, a debate over whether these products are securities has already begun.

Korea's next round of digital asset law is the place to settle these questions, so that domestic institutions can compete in on-chain asset management with clear rules.

Adapted from eToday: 김효봉 변호사 “규제 명확성 위해 업계 전문성 활용한 법적 근거 마련 필요” (Korean).

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