[EXHIBIT 8.1]




                                 May 2, 2000




Hanmi Financial Corporation
3660 Wilshire Boulevard
Los Angeles, CA 90010


Re:       Hanmi Financial Corporation

Gentlemen:

         We have acted as counsel to Hanmi Financial Corporation ("Hanmi
Financial"), a Delaware corporation, in connection with the proposed
reorganization of Hanmi Bank (the "Reorganization") pursuant to which Merger
Co., a California corporation ("Merger Co."), a newly formed wholly owned
subsidiary of Hanmi Financial, will merge with and into Hanmi Bank. The
Reorganization will be completed pursuant to the terms of the Plan of
Reorganization and Agreement of Merger dated as of April 15, 2000 by and
among Hanmi Bank, Hanmi Financial, and Merger Co. (the "Reorganization
Agreement") and as described in the Registration Statement (No. 333-32770) on
Form S-4 filed by Hanmi Financial (the "Registration  Statement"). This
opinion is being rendered pursuant to your request. All capitalized terms,
unless otherwise specified, have the meaning assigned to them in the
Reorganization Agreement.

         In connection with this opinion, we have examined and are familiar
with originals or copies, certified or otherwise identified to our
satisfaction, of (i) the Reorganization Agreement, (ii) the Registration
Statement, and (iii) such other documents as we have deemed necessary or
appropriate in order to enable us to render the opinion below. In our
examination, we have assumed the genuineness of all signatures, the legal
capacity of all natural persons, the authenticity of all documents submitted
to us as originals, the conformity to original documents of all documents
submitted to us as certified, conformed or photostatic copies and the
authenticity of the originals of such copies. In rendering the opinion set
forth below, with regard to certain factual matters, we have relied upon
certain written representations and covenants of Hanmi Bank and Hanmi
Financial.

         In rendering our opinion, we have considered the applicable
provisions of the Internal Revenue Code of 1986, as amended (the "Code"),
Treasury Regulations, pertinent judicial authorities, interpretive rulings of
the Internal Review Service and such other authorities as we have considered
relevant.



Hanmi Financial Corporation
May 2, 2000
Page 2


         Based upon and subject to the foregoing, we are of the opinion that
the Reorganization will, under current law, constitute a tax-free
reorganization under Section 368(a) of the Code, and Hanmi Bank and Hanmi
Financial will each be a party to a "reorganization" within the meaning of
Section 368(b) of the Code.

         As a tax-free reorganization, the Reorganization will have the
following Federal income tax consequences:

         1.  No gain or loss will be recognized by Hanmi Bank, Merger
Co., or Hanmi Financial as a result of the Reorganization;

         2.  No gain or loss will be recognized by the shareholders of Hanmi
Bank upon receipt of Hanmi Financial common stock in exchange for their
shares of Hanmi Bank common stock pursuant to the Reorganization;

         3.  The basis of the Hanmi Financial common stock received by
the shareholders of Hanmi Bank pursuant to the Reorganization will be the
same as the basis of the shares of Hanmi Bank common stock surrendered
in exchange therefor;

         4.  The holding period of the Hanmi Financial common stock received
by shareholders of Hanmi Bank pursuant to the Reorganization will include
the holding period of the Hanmi Bank common stock surrendered in exchange
therefor, provided that such Hanmi Bank common stock is held as a capital
asset on the date of consummation of the Reorganization; and

         5.  A holder of an outstanding option granted under the Hanmi Bank
1992 Stock Option Plan will not recognize income, gain, or loss solely as a
result of the exchange of the outstanding option for an identical option
issued under the Hanmi Financial Year 2000 Stock Option Plan.

         This opinion is solely for your information and the shareholders of
record (as defined in the Registration Statement) in connection with the
issuance of the shares common stock by the Company, and is not, without the
prior written consent of this firm, to be quoted in full or in part or
otherwise referred to in any documents nor to be filed with any



Hanmi Financial Corporation
May 2, 2000
Page 3



governmental agency or other persons, other than with the Commission and
various state securities administrators in connection with the qualification
of the Shares, to which reference and filings we hereby consent.

                                        Very truly yours,


                                        /s/ BUCHALTER, NEMER, FIELDS & YOUNGER
                                        A Professional Corporation