South Korean Government Amends Public Notice on Trade of Strategic Items Implementing Export Controls

Since the club’s news item of 24 March 2022, the South Korean government has introduced additional measures against Russia, including strategic export controls.  This has been done via the Public Notice on Trade of Strategic Items ('Public Notice') issued by the Ministry of Trade, Industry, and Energy ('MOTIE') on 25 March 2022, which came into effect as of 26 March 2022.

The Public Notice is a partial amendment to the sanction measures introduced by South Korea earlier this month. The Public Notice adds 57 categories of goods that are currently not strategic items under South Korean law, but which are items subject to the expanded U.S. export controls targeting Russia imposed by the U.S. Department of Commerce on 24 February 2022. The additional 57 categories in Annex 2-2 all fall into one of the categories outlined below:

1. Electronics and semiconductor
2. Computers
3. Telecommunications
4. Information security, sensors and lasers
5. Navigation and avionics
6. Marine
7. Aerospace and propulsion

Annex 2-2 lists items which are subject to a ‘situational license’ (i.e. license under catch-all controls) under the Public Notice (see the copy of Annex 2-2 in English as attached). For those companies that trade to Russia any of the 57 additional items now listed in Annex 2-2, it is understood that a specific license needs to be obtained from the MOTIE at first instance.  

We urge our members to check the position against the Public Notice and carry out all the necessary due diligence. Please see the details of the press releases on this on the MOTIE website here.

We strongly recommend that members keep the rapidly evolving sanctions against Russia under close review, including potential further South Korean sanctions.  We will continue to closely monitor the situation and update you about any further developments. If you have any queries in the meantime, please reach out to your usual club contact.

Categories: Sanctions, Ukraine / Russia