SOUTH KOREA Trends and Developments Contributed by: Hwan Kyoung Ko, Hyunjun Kim, Kyung Min Son and Matt Younghoon Mok, Lee & Ko
Notable enforcement actions against foreign businesses in 2024 include the following: • 4 November – Administrative penalties of approximately KRW21.6 billion (approximately USD14.8 million) on Meta Platforms, Inc for collecting and utilising sensitive information without legal basis and refusing data sub - jects’ access to their personal information without justifiable reasons. • 24 July – Administrative penalties of approxi - mately KRW2 billion (approximately USD1.4 million) on Alibaba.com Singapore E-Com - merce Private Limited for violating regulations related to the cross-border transfer of per - sonal information. • 25 September – Administrative penalties of approximately KRW1.1 billion (approximately USD750,000) on Worldcoin Foundation and Tools for Humanity Corporation for violating obligations regarding sensitive information processing restrictions. In particular, the PIPC’s press release for the Meta enforcement action sent a clear message to foreign business operators that “foreign busi - nesses operating global services must comply with Korean PIPA requirements”, emphasising the “non-discriminatory application of PIPA to global companies serving Korean users”. This marked a decisive shift towards more rigor - ous enforcement of data protection regulations against foreign entities. Another point of particular concern is the regu - lator’s proactive approach to emerging tech - nologies, especially AI. From November 2023 to March 2024, the PIPC conducted preliminary compliance inspections of businesses develop - ing or deploying large language models (LLMs) or LLM-based services. This initiative, which included major international players such as
OpenAI, Google, Microsoft and Meta, led to comprehensive improvement recommendations being issued on 27 March 2024. The PIPC has explicitly committed to ongoing monitoring of “AI technological and industrial changes, includ - ing AI model advancement and proliferation of open-source models”, signalling sustained regu - latory attention in this rapidly evolving sector. The IT sector In 2024, South Korea’s IT regulatory authori - ties significantly strengthened their oversight of global technology companies, with both the MSIT and the KCC taking decisive enforcement actions and pursuing legislative changes to enhance their regulatory framework. The KCC’s enforcement activities in 2024 dem - onstrated its commitment to robust oversight of foreign IT companies. On 23 February 2024, the regulator imposed administrative penalties and fines of approximately KRW450 million (approximately USD310,000) on Twitch for mul - tiple violations, including unjustified restrictions on streaming quality, unilateral discontinuation of VOD services, and failure to implement ade - quate technical measures against illegal content distribution. In another significant action, on 7 November 2024, the KCC formally mandated Telegram to designate a youth protection officer and implement comprehensive measures for monitoring and managing content that could be harmful to young people, marking an enhanced focus on content moderation obligations for for - eign messaging platforms. The regulatory scope extended beyond content and service issues to encompass system reliabil - ity. Following the 2022 nationwide disruption of Korea’s largest messenger service due to a data centre fire, the Framework Act on Broadcasting Communications Development was amended to
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