SOUTH KOREA Law and Practice Contributed by: Jeena Kim, Sodam Kim and Bochan Kim, Bae, Kim & Lee LLC
Bae, Kim & Lee LLC Centropolis B 26 Ujeongguk-ro Jongno-gu Seoul 03161 Korea Tel: +82 2 3404 0000 Fax: +82 2 3404 0001 Email: bkl@bkl.co.kr Web: www.bkl.co.kr/law?lang=en
1. Trends and Overview 1.1 Sanctions Market
the government also announced its intention to sanc - tion overseas North Korean IT personnel and institu - tions involved in foreign currency-earning operations used to fund the country’s nuclear and missile pro - grammes. Strengthening the Export Control Framework In the area of export controls, South Korea has con - tinued to align its measures with those of the United States (US), particularly regarding Russia and Bela - rus. One key development was the expansion of the so-called situational-licence list, which covers items that are not generally classified as strategic items but still require export approval from the Ministry of Trade, Industry and Energy (MOTIE) due to their potential risk of being diverted for use in weapons of mass destruction. To this end, the MOTIE issued a notifica - tion, effective 24 February 2024, adding 682 items to the list, which included heavy construction machin - ery, secondary batteries, machine tools and aircraft components. A subsequent notification, effective 9 September 2024, added a further 243 items consid - ered to have a high risk of military end use, including metal-cutting machines, machine-tool components, optical-device parts and sensors. With these addi - tions, the total number of items requiring a situational licence for export to Russia and Belarus rose to 1,402. Additionally, the MOTIE issued a notification, effec - tive 28 February 28, designating an additional 21 advanced-industry items and technologies – covered under international regimes such as the Wassenaar Arrangement, the Nuclear Suppliers Group, the Mis - sile Technology Control Regime and the Australia
Compared to 12 months ago, the sanctions landscape may be poised for change following the inauguration of President Lee Jae-myung in June 2025. The Demo - cratic Party, to which the new president belongs, has historically adopted a more conciliatory stance toward North Korea. As such, his administration is expected to take a more moderate approach than the previous government, which had implemented multiple sanc - tions against North Korea. However, as his presidency has only begun, it remains too early to assess whether any substantive changes to the existing sanctions regime have occurred. 1.2 Key Trends Increased Sanctions Against North Korea Over the past 12 months, South Korea has imposed multiple unilateral sanctions on North Korea in response to its continued nuclear and missile activi - ties, in line with broader international sanctions regimes. Specifically, on 2 April, 24 May, 1 July, and 19 December 2024, South Korea designated individu - als and entities that violated United Nations Security Council (UN) resolutions as sanctioned parties under its own sanctions framework. These individuals and entities were involved in illicit Russia-North Korea military co-operation and in the financing or supply of materials supporting North Korea’s weapons pro - grammes. Additional sanctions were imposed on 18 July 2024 and 10 April 2025, targeting vessels, organi - sations and individuals similarly engaged in activities contravening UN sanctions. On 26 December 2024,
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