Unpacking Upbit's Bitcoin Accumulation Strategy: A Deep Dive into DCA and Holdings

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As the cryptocurrency landscape evolves, the strategies of major exchanges often provide key insights into market trends and operational philosophies. Among these, South Korea's largest exchange, Upbit, has developed a notable approach to Bitcoin accumulation that merits closer examination. By leveraging its unique revenue streams, Upbit's operator, Dunamu, has amassed a significant Bitcoin treasury, positioning it among the top corporate holders globally.

This analysis explores the mechanics behind Upbit’s Bitcoin strategy, the challenges it faces, and the potential implications for its future growth and valuation.

How Upbit Generates and Accumulates Bitcoin

Upbit’s primary business model revolves around two core services: cryptocurrency trading and staking. However, its ability to accumulate Bitcoin specifically stems from certain fee structures and operational practices.

Transaction Fees in Bitcoin Markets

Upbit operates multiple trading markets, including a Korean Won (KRW) market, a Bitcoin (BTC) market, and a Tether (USDT) market. In the BTC market, the exchange charges a 0.25% fee on both the buyer and seller for each transaction, collected in Bitcoin. This creates a direct and continuous inflow of BTC based on trading activity.

Bitcoin Withdrawal Fees

When users withdraw Bitcoin from the platform, Upbit charges a network fee. As of mid-2025, this fee was set at 0.0008 BTC per withdrawal. While the actual cost to Upbit for processing these on-chain transactions is often significantly lower, the difference contributes to its Bitcoin reserves.

Other Potential Revenue Streams

Dunamu has technical and brand partnerships with other global exchanges, such as Upbit APAC. Though specific contractual details are undisclosed, these alliances may include revenue-sharing arrangements that could contribute additional Bitcoin, albeit likely in smaller quantities.

From an accounting perspective, Bitcoin collected through these methods is recorded as an intangible asset. Revenue is recognized at the time of transaction or withdrawal, and the corresponding Bitcoin is added to Dunamu’s balance sheet.

The Scale of Upbit’s Bitcoin Holdings

By the end of 2024, Dunamu held 16,839 BTC, worth approximately $1.8 billion at the time. This placed it as the fourth-largest Bitcoin holder among publicly listed companies globally and within the top ten包括 private entities.

The growth has been rapid. Starting from just 195 BTC at the end of 2019, Dunamu expanded its holdings dramatically over five years. In 2023 alone, it accumulated 3,918 BTC, representing over 13% of its total revenue that year. In 2024, it added 917 BTC.

This accumulation strategy functions similarly to dollar-cost averaging (DCA), where a fixed portion of revenue is consistently used to acquire Bitcoin, regardless of short-term price fluctuations.

Challenges to Sustaining Accumulation

Despite past success, several market and structural factors threaten Dunamu’s ability to maintain this pace of Bitcoin accumulation.

Declining Transaction Volumes

The approval of Bitcoin spot ETFs in the United States in early 2024 altered market behavior. As Bitcoin became more widely regarded as a store of value rather than a medium of exchange, trading volumes on Upbit’s BTC markets fell sharply.

This decline directly reduces the amount of Bitcoin collected via trading fees.

Competitive Pressure on Withdrawal Fees

Upbit’s withdrawal fee, though profitable, is significantly higher than many international competitors. For example:

As global competition intensifies and technologies like the Lightning Network gain adoption for cheaper transactions, Upbit may face pressure to reduce its withdrawal fees, cutting into this revenue stream.

Operational and Regulatory Factors

Dunamu’s ability to dispose of or use its Bitcoin has been influenced by local regulations. In the past, restrictions on corporate cryptocurrency accounts may have limited its options, effectively forcing it to hold BTC. However, recent regulatory clarifications have allowed greater flexibility. From 2025 onward, companies and exchanges can more freely dispose of cryptocurrencies, which might lead Dunamu to change its strategy.

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Implications for Valuation and Market Perception

Dunamu’s market valuation of approximately $3.9 billion (as of 2025) may not fully account for its Bitcoin holdings. The increase in equity due to Bitcoin revaluation—amounting to $1.1 billion in 2024—is not reflected in operating profit or net income figures, potentially leading to undervaluation by investors who focus solely on earnings metrics.

Comparisons with global peers like Coinbase are challenging due to differing business models. Coinbase has a more diversified portfolio, including its own blockchain (Base), derivatives trading, and plans for futures markets. Nonetheless, Dunamu’s significant Bitcoin reserves should be considered in any comparative valuation.

Investors should note that future accumulation rates are unlikely to match past performance. Assuming that Dunamu will continue to acquire Bitcoin at the same pace could lead to overvaluation.

Frequently Asked Questions

How does Upbit make money from Bitcoin?
Upbit earns Bitcoin primarily through trading fees in its BTC markets and via withdrawal fees when users transfer BTC off the exchange. These streams are automatically accumulated as part of its treasury.

Why can’t Upbit sustain its Bitcoin accumulation?
Bitcoin trading volumes on the platform have dropped significantly since the introduction of spot ETFs, reducing fee income. Additionally, competitive pressures may force Upbit to lower its withdrawal fees, further limiting this revenue source.

What is a Bitcoin maximalist strategy?
A Bitcoin maximalist focuses primarily on Bitcoin, often believing it will outperform other cryptocurrencies. Dunamu’s practice of converting much of its revenue into BTC aligns with this approach, though it may be partly driven by past regulatory constraints.

How does Dunamu’s Bitcoin holding affect its valuation?
The value of Dunamu’s Bitcoin reserve adds significantly to its equity. However, since this gain isn’t reflected in profit measures, some investors may overlook it, potentially leading to undervaluation.

Are there other companies like Dunamu?
Tether Limited has also used operating profits to buy Bitcoin, though most companies (like MicroStrategy) acquire BTC through debt or equity raises rather than organic revenue.

What could change Dunamu’s Bitcoin strategy?
Greater regulatory clarity and the ability to freely dispose of BTC may lead Dunamu to manage its holdings more actively, potentially selling portions for operational needs or investments.

Conclusion: A Strategy in Transition

Dunamu’s Bitcoin accumulation strategy has been remarkably effective, positioning it as a major corporate holder. However, market changes and increased competition suggest that the rapid growth of its BTC treasury may slow.

The decline in Bitcoin trading activity and potential fee reductions will likely reduce organic Bitcoin inflows. Meanwhile, regulatory changes offer Dunamu more flexibility in managing its holdings, which could lead to a shift from accumulation to active management.

For market observers and investors, understanding these dynamics is crucial. Dunamu’s journey reflects broader trends in the cryptocurrency industry, where exchanges must adapt to evolving market structures and regulatory environments.

While Dunamu has exemplified a Bitcoin-focused approach, its future steps will depend on balancing operational needs, market opportunities, and strategic goals. Keeping an eye on its quarterly financial disclosures and Bitcoin movement will provide further insights into its evolving strategy.