원화 스테이블코인 규제 패러다임의 전환: 발행자 중심 규율체계에서 사용자·거래 기반 규율체계로 ― 사용처별 편익 측정모형과 거래속성 기반 법률 연계를 중심으로 ―

초록

The discussion on Korean Won (KRW) stablecoins has largely focused on supply-side regulatory issues such as issuer licensing, reserve assets, redemption rights, and foreign-exchange stability. The institutional case for a payment instrument, however, also depends on what benefits users obtain and how each transaction is connected to existing legal regimes. This article presents an analytical framework that evaluates net benefits across use cases by separating them into payment fee savings, working-capital gains, foreign-exchange cost savings, refund and dispute costs, documentary and accounting automation benefits, programmable payment benefits, and compliance costs. It further formalizes adoption threshold conditions and proposes a transaction-attribute-based legal linkage model that connects electronic finance, foreign exchange, AML/CFT, consumer protection, and capital market rules. It also examines functional responsibility sharing between issuers and service providers and discusses how the proposed framework can inform pilot design, supervisory reporting, and future rulemaking.

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