How Upbit’s Bitcoin DCA Strategy Built a $1.8B Crypto Treasury

In the evolving landscape of digital finance, few corporate strategies have drawn as much quiet attention as Upbit’s organic accumulation of Bitcoin. Operated by South Korea’s Dunamu Inc., Upbit has quietly amassed 16,839 BTC—worth approximately $1.8 billion as of late 2024—placing it among the top Bitcoin-holding public companies globally. This wasn’t achieved through fundraising or debt financing, but via a self-reinforcing business model that effectively functions as a continuous dollar-cost averaging (DCA) strategy, fueled by transaction fees and withdrawals.

This article explores how Upbit transformed routine exchange operations into one of the most compelling examples of organic Bitcoin accumulation, analyzes the sustainability of this strategy amid shifting market dynamics, and evaluates its implications for corporate valuation and long-term crypto adoption.

The Rise of Bitcoin as a Corporate Asset

Over the past decade, Bitcoin has evolved from an experimental digital currency into a recognized store of value. The approval of spot Bitcoin ETFs in the U.S. in 2024 marked a pivotal moment, legitimizing BTC as a viable institutional asset class. With growing macroeconomic uncertainty and increasing interest in decentralized financial infrastructure, more corporations are integrating Bitcoin into their treasury strategies.

While companies like MicroStrategy and Tether have made headlines for their aggressive BTC purchases, often funded through debt or capital raises, Dunamu stands out for a different reason: it funds its Bitcoin acquisitions through operational cash flow. Unlike one-time strategic buys, Upbit’s model reflects a continuous, organic process—effectively “buying” Bitcoin every time a user trades or withdraws BTC on the platform.

This makes Dunamu one of the rare examples of a company using real-time revenue generation to accumulate Bitcoin without relying on external financing.

Dunamu’s Bitcoin Accumulation Engine: How It Works

As of December 2024, Dunamu held 16,839 BTC, up from just 195 BTC at the end of 2019. This rapid growth was not accidental—it was built into Upbit’s core revenue model.

The accumulation occurs primarily through two streams:

1. Bitcoin Market Trading Fees
2. Bitcoin Withdrawal Fees

1. BTC Market Trading Fees: The Primary Fuel

Upbit operates three main trading markets:

• KRW-BTC pairs (Korean won against crypto)
• BTC-Altcoin pairs (Bitcoin against other cryptocurrencies)
• USDT-Altcoin pairs

For every trade executed in the BTC market, Upbit charges both the buyer and seller 0.25% in BTC, totaling 0.5% per transaction. These fees are collected directly in Bitcoin and recorded as revenue.

From an accounting perspective, when users pay fees in BTC:

• Debit: Intangible Assets (Bitcoin)
• Credit: Revenue

This means each fee collection increases Dunamu’s BTC holdings on its balance sheet—effectively functioning as a micro-purchase of Bitcoin with every trade.

In 2023 alone, Upbit collected an estimated 3,481 BTC from BTC market fees. Even in 2024, despite declining volumes, it still generated 826 BTC from this source.

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2. BTC Withdrawal Fees: A High-Margin Revenue Stream

When users withdraw Bitcoin from Upbit, they are charged a flat fee—historically ranging from 0.0008 to 0.0009 BTC per transaction.

Compare this to actual on-chain network costs: during average congestion periods, miners receive around 0.00002–0.00003 BTC in fees. This implies a gross margin exceeding 96%, even after accounting for operational overhead.

While withdrawal volume is limited compared to trading activity, these fees still contributed:

• 437 BTC in 2023
• 91 BTC in 2024

Although withdrawals represent less than 10% of total BTC inflows, they remain a high-margin, low-effort income stream.

3. Potential Third Source: International Licensing Revenue

Dunamu has technical partnerships with international exchanges under the "Upbit" brand, such as in Thailand and Indonesia. While not fully transparent, there is evidence that fee-sharing agreements may transfer BTC-denominated revenue back to Dunamu.

For example:

• Upbit Thailand reported paying "system service fees" to Dunamu Inc.
• API data suggests shared liquidity pools in certain markets.

However, due to limited disclosure and small scale relative to domestic operations, this channel likely contributes less than 10 BTC annually—insignificant compared to core revenue streams.

Can Upbit Sustain Its Bitcoin Accumulation?

Despite its impressive track record, several structural shifts threaten the continuity of this DCA-like strategy.

Declining BTC Market Trading Volume

The most critical trend is the sharp drop in Bitcoin-based trading volume on Upbit:

* As of May 2025

This represents a 96.4% decline from 2023 levels, largely attributed to changing market behavior post-spot ETF approval. Investors now view Bitcoin primarily as a store of value, not a medium for trading altcoins—reducing demand for BTC/alt pairs.

Without intervention, this trend suggests Upbit could generate less than 150 BTC per year from trading fees going forward—down from nearly 4,000 BTC in 2023.

Intensifying Competition on Withdrawal Fees

Globally, major exchanges like Binance and OKX charge between 0.00002–0.00003 BTC for withdrawals—up to 40 times lower than Upbit’s current rate.

Even if Upbit maintains its fee structure today, competitive pressure will likely force reductions over time. If fees fall to global standards, annual BTC income from withdrawals could shrink to under 30 BTC.

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Financial Implications and Valuation Considerations

Dunamu’s current market cap sits at around $3.9 billion, yet few analysts incorporate its Bitcoin holdings into valuation models.

Key overlooked factors include:

• In late 2024, revaluation of its Bitcoin holdings added $1.1 billion to equity—recorded under intangible assets, not profit.
• This unrealized gain does not appear in P&L statements and may be ignored by traditional investors.
• When adjusting for BTC reserves, Dunamu appears significantly undervalued compared to peers like Coinbase—especially considering its purely operational accumulation method.

However, caution is warranted: future accumulation rates are unlikely to match past performance. Any valuation premised on continued high-speed BTC growth risks overestimation.

Frequently Asked Questions (FAQ)

Q: How does Upbit "buy" Bitcoin without spending cash?

A: Upbit doesn’t use cash to purchase Bitcoin. Instead, it receives BTC directly as payment for services—trading fees and withdrawal fees—which are recorded as revenue and held as intangible assets on its balance sheet. This creates a natural DCA effect funded by user activity.

Q: Is Dunamu intentionally accumulating Bitcoin?

A: There’s no public statement confirming a deliberate strategy. However, regulatory restrictions on corporate crypto disposal in South Korea until early 2025 may have effectively forced Dunamu to hold rather than sell incoming BTC—a policy-driven form of Bitcoin maximalism.

Q: Why has BTC market trading volume dropped so sharply?

A: After the U.S. approved spot Bitcoin ETFs in early 2024, investor perception shifted toward treating Bitcoin as a long-term store of value rather than a trading asset. As a result, fewer users trade altcoins against BTC, preferring to hold or trade via USD/USDT pairs.

Q: Could Dunamu start selling its Bitcoin?

A: Yes. Regulatory clarity introduced in 2025 now allows Korean firms to dispose of crypto assets more freely. While no sales have been reported yet, this opens the possibility that Dunamu could monetize part of its holdings—or even pivot away from passive accumulation.

Q: How does Upbit compare to MicroStrategy or Tether?

A: Unlike MicroStrategy (which uses debt financing) or Tether (which allocates profits), Upbit accumulates Bitcoin purely through operational income. This makes its model unique—organic, scalable with volume, but vulnerable to market shifts affecting fee revenue.

Q: What could revive Upbit’s BTC accumulation?

A: Potential solutions include launching new products (e.g., perpetual futures, options), expanding globally with competitive withdrawal fees, or introducing tokenized financial instruments tied to BTC yields—all aimed at boosting transaction volume and user engagement.

Conclusion: A Model at a Crossroads

Dunamu has executed one of the most fascinating case studies in organic Bitcoin adoption. By aligning its business model with BTC inflows, it became the fourth-largest publicly traded corporate holder of Bitcoin, amassing over 16,800 BTC without issuing shares or taking on debt.

Yet structural headwinds—declining trading volumes and competitive fee pressure—make it unlikely that this pace can continue. Unless Dunamu diversifies its services or expands internationally, its era of rapid accumulation may be ending.

Still, the company’s journey offers valuable lessons:

• Operational cash flow can power sustainable crypto adoption.
• Regulatory environments shape corporate crypto behavior as much as strategy.
• Market perception of Bitcoin directly impacts exchange economics.

As the crypto ecosystem matures, watch whether Dunamu evolves from a passive accumulator into an active steward of its $1.8B digital treasury—or becomes a cautionary tale of a model disrupted by changing user behavior.

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