Sanctions 2025

SOUTH KOREA Law and Practice Contributed by: Jeena Kim, Sodam Kim and Bochan Kim, Bae, Kim & Lee LLC

Group – as strategic items that could be exported despite their connections to sanctioned countries. Under this revision, certain medical devices intended for humanitarian use (eg, diagnostic X-ray and radio - graphic imaging systems) with a low risk of military diversion may now be exported to Russia without a situational licence, provided that appropriate docu - mentation is submitted. Separately, a July 2024 amendment to the Enforce - ment Decree of the Foreign Trade Act established a legal basis for South Korea to implement unilateral export control measures independently of internation - al regimes. However, no such independent designa - tions have been made to date. 1.3 Key Industries The manufacturing industry, including insofar as it is related to batteries, automobiles, steel and semicon - ductors, continues to be most affected by the trade sanctions regulations of the US. A report dated 28 April 2025, issued by the International Trade and Commerce Research Institute of the Korea Interna - tional Trade Association, revealed that over 60% of South Korean companies were considering adjusting their global supply chains to comply with US trade sanctions. This concern was particularly observed in companies trading secondary batteries, automobiles and automotive parts, steel and metals, computers, telecommunications equipment and networks, and semiconductors, among others. 1.4 Overview 1.4.1 Types of Sanctions South Korea implements a range of sanctions, includ - ing trade restrictions (such as arms embargoes), eco - nomic and financial measures, including asset freez - es, travel prohibitions, as well as aviation and maritime sanctions. 1.4.2 Scope of Sanctions As a general rule, South Korean laws apply (i) to Korean nationals, wherever located, and (ii) all enti - ties and individuals within Korean territory. However, sanctions may also have extra-territorial reach and apply to foreign nationals, in accordance with general principles of criminal jurisdiction. For example, Korean sanctions may apply to offences committed abroad

against Korean nationals or the Korean government, or to foreign exchange transactions with a Korean nexus, such as those involving Korean residents or the Korean currency. 1.4.3 Domestic and/or Supranational Measures South Korea imposes sanctions both independently under its domestic laws and in co-ordination with international measures. Although South Korean law permits unilateral sanctions, the government generally aligns its actions with those of international bodies or key allies, such as the UN, US, and the European Union (EU) by incorporating their measures into its domestic framework. Legal Basis for Sanctions Implementation The key statutes and regulations that incorporate international sanctions into the Korean legal system include the following. • Foreign Trade Act – implements trade-related sanc - tions, mainly for dual-use items. • Foreign Exchange Transactions Act and the Act on Prohibition against the Financing of Terrorism and Proliferation of Weapons of Mass Destruction (“Anti-Terrorism Act”) – provides the basis for eco - nomic and financial sanctions. • Immigration Control Act, Customs Act, Coast Guard Affairs Act, Act on Arrival and Departure of Ships, and Aviation Safety Act – implement travel bans, aviation bans and maritime sanctions. • Public Notice on Special Trade Measure for Imple - mentation of Obligation for Maintaining Internation - al Peace and Security (“Public Notice on Special Trade Measure”) – serves as a key administrative tool for implementing UN and allied sanctions. Financial Sanctions In addition to the Foreign Exchange Transactions Act and Anti-Terrorism Act, the following regulations spe - cifically govern financial sanctions in South Korea: (i) the Guidelines on Payment and Receipt of Payment to Perform Duties to Maintain International Peace and Security, and (ii) the Regulation on the Designation of Persons as Subject to Financial Transaction Restric - tions and the Revocation of Such Designation.

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