According to CoinMeta, the share exchange transaction between Dunamu and NAVER Pay under NAVER may face conflicts with the maximum shareholding limits. Data disclosed by the Legislative Investigation Office of the South Korean National Assembly shows that Dunamu, as the parent company of Upbit, may simultaneously be subject to the minimum shareholding requirements of the Fair Trade Act for subsidiaries, as well as the maximum shareholding restrictions for major shareholders of virtual asset exchanges. Currently, NAVER Pay does not seem to be a holding company; however, if it were to become one in the future and incorporate the exchange as a subsidiary, two conflicting shareholding standards could apply simultaneously, or adjustments to its governance structure may be necessary. The Fair Trade Act stipulates that a holding company's shareholding in a listed subsidiary must not be less than 30%, and for unlisted subsidiaries, it must not be less than 50%. For venture capital holding companies, the required shareholding is 20%.