13 Banking Regulation Review - Korea

8/13/2019 '13 Banking Regulation Review - Korea

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The BankingRegulation

Review

Law Business Research

Fourth Edition

Editor

Jan Putnis


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The Banking Regulation Review

Reproduced with permission from Law Business Research Ltd.

Tis article was first published in Te Banking Regulation Review, 4th edition

(published in April 2013 editor Jan Putnis).

For further information please [email protected]


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The Banking

Regulation

Review

Fourth Edition

Editor

J P

L B R L


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PUBLISHERGideon Roberton

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Published in the United Kingdomby Law Business Research Ltd, London

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2013 Law Business Research Ltdwww.TeLawReviews.co.uk

No photocopying: copyright licences do not apply.Te information provided in this publication is general and may not apply in a specificsituation. Legal advice should always be sought before taking any legal action based on

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el: 0844 2480 112


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i

Te publisher acknowledges and thanks the following law firms for their learnedassistance throughout the preparation of this book:

ADVOKAFIRMAE BAHR DA

AFRIDI & ANGELL

ALI BUDIARDJO, NUGROHO, REKSODIPURO

ANDERSON MRI & OMOSUNE

ARHUR COX

BONELLI EREDE PAPPALARDO

BREDIN PRA

BUN & ASSOCIAES

CHANCERY CHAMBERS

CLAYON UZ

CONSORIUM ABOADA & ASOCIADOS

CONSORIUM CENRO AMRICA ABOGADOS

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DAVIS POLK & WARDWELL LLP

DE BRAUW BLACKSONE WESBROEK

DLA PIPER WEISSESSBACH RECHSANWLE GMBH

ACKNOWLEDGEMENTS


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ii

Acknowledgements

ELVINGER, HOSS & PRUSSEN

F.O. AKINRELE & CO

FERRERE ABOGADOS

GERNAND & DANIELSSON

GIDE LOYREE NOUEL AARPIHANNES SNELLMAN

HENGELER MUELLER

KADIR, ANDRI & PARNERS

KBH KAANUUN

KIM & CHANG

LENZ & SAEHELIN

LS HORIZON LIMIED

MAOS FILHO ADVOGADOS

MAYORA & MAYORA, SC

MIRANDA CORREIA AMENDOEIRA & ASSOCIADOS

MKONO & CO ADVOCAES

MORAIS PASSAS LAW FIRM

MOURAN OZANNES

MULLA & MULLA & CRAIGIE BLUN & CAROE

NAGY S RCSNYI GYVDI IRODA

NAUADUILH

PAKSOY


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Acknowledgements

iii

PELIFILIP SCA

PIMENA DIONISIO E ASSOCIADOS

RUSSELL MVEAGH

SHALAKANY LAW OFFICE

SKUDRA & UDRISSLAUGHER AND MAY

SYCIP SALAZAR HERNANDEZ & GAMAIAN

SUDNICKI, K PESZKA, Z WIKALSKI, J GRSKI SPK

URA MENNDEZ

VASIL KISIL & PARNERS

VIEIRA DE ALMEIDA & ASSOCIADOS

WASELIUS & WIS

WEBBER WENZEL

ZHONG LUN LAW FIRM


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iv

CONTENTS

Editors Preface ...................................................................................................xi Jan Putnis

Chapter 1 INERNAIONAL INIIAIVES ......................................... 1Jan Putnis and olek Petch

Chapter 2 ANGOLA ................................................................................ 34Mafalda Oliveira Monteiro and Bruno Sampaio Santos

Chapter 3 AUSRALIA............................................................................ 45

Louise McCoach and David Landy

Chapter 4 AUSRIA ................................................................................ 85Wolfgang Freund

Chapter 5 BARBADOS ............................................................................ 95revor A Carmichael QC

Chapter 6 BELGIUM ............................................................................. 104

Anne Fontaine

Chapter 7 BOLIVIA ............................................................................... 115Carlos Pinto-Meyer and Cristian Bustos

Chapter 8 BRAZIL ................................................................................. 123Jos Eduardo Carneiro Queiroz

Chapter 9 CAMBODIA ......................................................................... 129

Bun Youdy

Chapter 10 CANADA .............................................................................. 145Scott Hyman, Carol Pennycook, Derek Vesey and Nicholas Williams

Chapter 11 CAYMAN ISLANDS ............................................................. 161Richard de Basto


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Chapter 12 CHINA .................................................................................. 172Wantao Yang and Borong Liu

Chapter 13 DENMARK ........................................................................... 193Mikkel Fritsch and anja Lind Melskens

Chapter 14 EGYP .................................................................................. 205Aly El Shalakany

Chapter 15 EL SALVADOR ..................................................................... 215Oscar Samour and Aquiles Delgado

Chapter 16 EUROPEAN UNION ........................................................... 226Jan Putnis and Michael Sholem

Chapter 17 FINLAND ............................................................................. 250arja Wist and Jussi Salo

Chapter 18 FRANCE ............................................................................... 262Olivier Saba, Samuel Pariente, Jennifer Downing, Jessica Chartierand Hubert Yu Zhang

Chapter 19 GERMANY ........................................................................... 295Tomas Paul and Sven H Schneider

Chapter 20 GREECE ............................................................................... 309

Dimitris Passas and Vassilis Saliaris

Chapter 21 GUAEMALA ....................................................................... 332Mara Fernanda Morales Pellecer

Chapter 22 GUERNSEY .......................................................................... 346John Lewis and Helen Wyatt

Chapter 23 HONG KONG ..................................................................... 358

Laurence Rudge and Peter Lake

Chapter 24 HUNGARY ........................................................................... 376Zoltn Varga and ams Psztor

Chapter 25 INDIA ................................................................................... 389Shardul Tacker


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Chapter 26 INDONESIA ......................................................................... 403Ferry P Madian and Yanny Meuthia S

Chapter 27 IRELAND.............................................................................. 426William Johnston, Robert Cain, Eoin OConnor and Niall Esler

Chapter 28 IALY .................................................................................... 440Giuseppe Rumi and Andrea Savigliano

Chapter 29 JAPAN ................................................................................... 452Hirohito Akagami and Wataru Ishii

Chapter 30 JERSEY .................................................................................. 464Simon Gould and Sarah Huelin

Chapter 31 KOREA .................................................................................. 476Sang Hwan Lee, Chan Moon Park and Hoin Lee

Chapter 32 KUWAI ............................................................................... 489Haifa Khunji and Basem Al Muthafer

Chapter 33 LAVIA ................................................................................. 503Armands Skudra

Chapter 34 LUXEMBOURG ................................................................... 514Franz Fayot

Chapter 35 MALAYSIA ............................................................................ 534Andri Aidham bin Dato Ahmad Badri, Julian Mahmud Hashimand an Kong Yam

Chapter 36 MALA .................................................................................. 544David Griscti and Clint Bennetti

Chapter 37 MOZAMBIQUE ................................................................... 555

Paulo Pimenta and Joo Leite

Chapter 38 NEHERLANDS ................................................................. 565Joost Schutte, Annick Houben and Mariken van Loopik

Chapter 39 NEW ZEALAND .................................................................. 579Guy Lethbridge and Debbie Booth


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Chapter 40 NICARAGUA ....................................................................... 592Rodrigo aboada R

Chapter 41 NIGERIA ............................................................................... 605Adamu M Usman and Jumoke Onigbogi

Chapter 42 NORWAY .............................................................................. 620erje Sommer, Richard Sjqvist and Markus Nilssen

Chapter 43 PHILIPPINES ....................................................................... 632Rafael A Morales

Chapter 44 POLAND .............................................................................. 648omasz Gizbert-Studnicki, omasz Spyra and Micha Bobrzyski

Chapter 45 PORUGAL .......................................................................... 662Pedro Cassiano Santos

Chapter 46 ROMANIA ............................................................................ 679Alexandru Birsan, Carmen Peli and Alexandra Manciulea

Chapter 47 SOUH AFRICA .................................................................. 692Johan de Lange and Matthew Gibson

Chapter 48 SPAIN .................................................................................... 704Juan Carlos Machuca

Chapter 49 SWEDEN .............................................................................. 732Niclas Rockborn and Nils Unckel

Chapter 50 SWIZERLAND .................................................................. 750Shelby R du Pasquier, Patrick Hnerwadel, Marcel ranchet andValrie Menoud

Chapter 51 ANZANIA ........................................................................... 773

Wilbert B Kapinga, Rehema A Khalid and Kamanga W Kapinga

Chapter 52 HAILAND .......................................................................... 783Montien Bunjarnondha and Rahat Alikhan

Chapter 53 URKEY ............................................................................... 798Serdar Paksoy and Nazl Bezirci


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EDITORS PREFACE

2012 may be remembered as the year when practical reality caught up with those whothought that the financial crisis that emerged in Western economies in 2007 wouldresult in more effective cooperation between financial regulators across the world. By onemeasure the number of new initiatives and proposals for reform the amount of cross-

border financial regulatory activism has never been higher. But by more useful measures moves towards solutions to the too big to fail problem through the developmentof effective cross-border resolution mechanisms for banking groups and internationalcooperation on reform of OC derivatives regulation the optimism of the past hasfaded a little.

Questions are increasingly asked about whether the obstacles to truly productivecross-border regulatory cooperation political imperatives, different incentives andstraightforward differences of view will ever be surmounted in ways that makeinternational banking groups fundamentally safer. Media speculation in January 2013

that US regulators might not allow banks to assume cross-border regulatory cooperationin the resolution plans that they prepare in 2013 would, if substantiated, highlight thistrend.

Tese apparently negative developments have not made the period since thepublication of the last edition of this book in April 2012 any less interesting. It is also

worth noting that most of the challenges that we have seen new law and regulation thatcreates difficult questions of cross-border consistency and extraterritoriality, differingregulatory philosophies between major financial jurisdictions and the sheer slowness

and unpredictability of developments have rational, if depressing, explanations. Forexample, fundamental differences between the insolvency law of major jurisdictions,coupled with cross-border recognition issues and disagreements over how to pay forresolution, are nothing if not formidable barriers to the development of workable group-

wide resolution plans for banking groups.However, the past 12 months have not been a period of complete failure of

regulatory reform either. Progress has been made, for example, in the enactment oflegislation regarding OC derivatives, most notably the European Market Infrastructure


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Editors Preface

Regulation (EMIR) in the European Union. But, as noted above, cross-bordercooperation in this area remains an issue: it seems that hardly a month goes by withoutthe discovery of a previously unremarked-upon anomaly between the rules in this areain different countries.

Bank liquidity regulation has continued to be the subject of intense debate in2012, culminating in the Basel Committees announcement in January 2013 of itsdecision to relax and to recommend the gradual phasing in of the liquidity coverageratio (LCR) for banks. aking into account the fundamental influence that the LCR

will have on many banks business models, this was a welcome sign of pragmatism andalso a sign of the Basel Committees willingness to move the debate on liquidity forward.

Despite the challenges that have arisen in bank resolution initiatives, legislationand rules are developing in this area in multiple jurisdictions, with, for example, thepublication of the draft European Union Recovery and Resolution Directive (the RRD)in June 2012.

Te European Union is, at the time of writing, enjoying a period of respitefrom the problems that it faced from the eurozone crisis in 2012, but it would be veryoptimistic to say that those problems have been brought under control. Te EuropeanCommission is placing much emphasis on finalising the legislation implementing BaselIII (CRD IV) and the RRD as soon as possible in 2013, notwithstanding that each ofthese initiatives may ultimately be affected profoundly by the parallel banking unionproposals for the eurozone.

In the United States, the main rules implementing Basel III are also expected tobe substantially finalised in 2013. Te significance of the restructuring of the financialregulatory regime in the United States, principally under the rules that are emergingfrom the framework established by the Dodd-Frank Act, continues to unfold and looksset to dominate the careers of a generation of regulators, bankers and their advisers.

Te realisation dawned on many banks in 2012 that regulatory reform will bea longer and more drawn-out process than had been anticipated. For this reason, 2012may also be remembered as the year when the banking sector in Europe, the UnitedStates and some other parts of the world began to think seriously about structural change

in the long term, accepting that restructuring will have to take place against a backdropof continuing regulatory reform. We have begun to see more group reorganisations,disposals, and the severe downsizing or closure of some businesses in banking groups,as well as opportunistic acquisitions. Four principal factors have contributed to thesedevelopments:a A little more certainty, or at least the perception of a little more certainty, about

rule-making (or, at least, the direction of rule-making) when compared to thepast.

b Te continuing urgent need that many banking groups have for capital andliquidity, and the related need to ensure that capital is deployed in the mostefficient and profitable ways.

c Some specific legal and regulatory initiatives driving structural change, such as theUS Volcker Rule (although this rule has not yet been fully defined at the time of

writing) and some emerging (though not yet in force) ring-fencing proposals inparts of Europe (so far principally in the United Kingdom and France).


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d Continuing regulatory attacks on complexity and actual or perceived barriers toresolution of banking groups.

Accordingly, many banks are refocusing their businesses (or are currently planning how

to do so) on what they consider to be the areas that will yield the highest returns relativeto cost in regulatory capital and liquidity terms. Consistent with that objective, we areseeing intense competition for capital allocation between different businesses withinbanking groups and a more widespread appreciation of the relative capital cost (or capitalefficiency) of different activities.

2012 was of course also marked by further recrimination about past practices inparts of the banking sector. Allegations that LIBOR and other benchmarks have beenmanipulated (or subject to attempted manipulation), continuing losses from mis-sellingand other past misconduct continue to affect the sector. Attention has turned morerecently to the ways in which banking groups quantify and present these problems intheir financial statements.

An increasingly orthodox view among senior management of banking groups inEurope and the United States is to conclude that the only way through these difficultiesis to adopt a whiter than white approach to compliance. Tis involves banks takingthe initiative to present a new way forward on compliance matters and breaking awayfrom the more reactive stance that some of them held in the past. Some commentatorshave asked where this will lead. Will it result in banking groups that are so hobbled

and diminished by internal policies and rules that innovation, efficiency and, ultimately,service to the real economy, is put at risk? Observation would suggest that this is aconcern unless banks keep in mind four critical objectives when developing theircompliance strategy and relationships with financial regulators:

ComplianceTe first and most obvious objective is to ensure that banking groups are and remaincompliant with their legal and regulatory obligations. In many countries this involvesdeveloping a good understanding of the purpose and spirit of those obligations in

addition to (or, in some cases, instead of ) their literal meaning.

PredictabilityIt is desirable to maximise the predictability of relationships with financial regulators.Good and constructive relationships with regulators generally make it more likely thatbanks will see what is coming around the corner sooner and will be better able to findpositive ways to plan ahead.

InfluenceConstructive influence of regulatory policy development in areas affecting banks is alsodesirable, even if a bank achieves no more than a small proportion of the change that it

would like to see. For this purpose I would include within the meaning of influence theconveying of cogent arguments even where regulators do not act in response to them.Tis is simply because the route to influence for a bank includes convincing regulatorsthat it has thoughtful and coherent ideas, even where political or other imperatives havethe result that the regulator does not address the banks concerns.


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Flexibility and pragmatismFlexibility and pragmatism in the relationships between banks and their regulators iscritical. Inflexibility can lead to inappropriate or overly formulaic regulatory approachesto unexpected developments. Flexibility is often difficult to achieve but is worth pursuing

in the interests of both banks and regulators, through regular informal contacts andexchanges of views with senior staff at regulators in addition to formal interactions.

Obvious-looking these objectives may be, but serious problems in relationships betweenbanks and their regulators can usually be traced back to a failure to achieve at least oneof them.

Tis updated edition contains submissions by authors provided for the most partbetween mid-January and mid-February 2013, covering 56 countries (in addition to thechapters on International Initiatives and the European Union). As ever, comments onthis book from banks, regulators and governments are welcome.

My thanks go to the contributors to this book, who have once again taken timeout from advising on important matters affecting the banking sector to update theirchapters update meaning a fundamental revision in many cases.

Tanks are also due to Adam Myers, Lydia Gerges and Gideon Roberton at LawBusiness Research Ltd, for their continuing support in the preparation of this book.

Finally, the list of credits would not be complete without mention of the partnersand staff of Slaughter and May, in particular Ruth Fox, Ben Kingsley, Peter Lake,

Laurence Rudge, Nick Bonsall, Ben Hammond, olek Petch and Michael Sholem. Onceagain, they helped not only to make this book possible but also to keep it as painless aproject as is currently possible in the field of banking regulation.

Jan Putnis

Slaughter and MayLondonMarch 2013


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Chapter 31

KOREA

Sang Hwan Lee, Chan Moon Park and Hoin Lee1

I INTRODUCTION

South Korea is home to a robust banking industry. Commercial banks throughout thecountry, including domestic banks, foreign bank branches and Korean subsidiaries of

foreign banks, play a key role in Koreas financial system and, in turn, have a large impacton the East Asian economy.

Banking activity in Korea has steadily increased in the past several decades asthe country has undergone rapid economic and political transformation. oday, sevennationwide and six regional domestic banks operate over 6,000 branches throughout thecountry, and approximately 40 foreign banks operate around 50 branches throughoutthe country.

Te financial services industry in Korea, including the banking sector, hastraditionally been subject to a prescriptive, rules-based regulatory framework with close

government supervision and frequent regulatory intervention. Over the past decade,however, steps have been taken to push financial regulation towards a more prospective,principles-based system with more flexibility built into it. Indeed, during the previousregime under President Lee Myung-bak, the government undertook a number of effortsaimed at deregulating the financial services industry and at privatising certain functionsand institutions that have traditionally been government-operated. While we expect thistrend to generally continue under the new President Park Geun-hye administration,

we also foresee more vigorous regulation and monitoring over the business activities of

financial institutions.Not immune to the global financial crisis and the eurozone debt crisis, Koreasfinancial markets have taken a severe hit in the past few years, and the government has

1 Sang Hwan Lee and Chan Moon Park are senior attorneys and Hoin Lee is a senior foreign

attorney at Kim & Chang.


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taken steps to build confidence in and ensure the stability of financial services institutions.Such policy emphasis of the government, combined with the significant efforts on thepart of the Korean banks to enhance its financial soundness, has resulted in Korean banksremaining relatively stable through the recent global financial crisis.

Strengthened regulation of financial institutions has recently become a globaltrend and Korea is no exception. Te Korean government has recently implemented,and is planning on implementing, additional regulations for corporate governanceof financial institutions and also for the compensation system for bank officers andemployees, as well as a bank levy to control the level of foreign currency assets held.Protection of financial consumers and regulation of corporate governance are expectedto be important policy points of the Park Geun-hye administration.

II THE REGULATORY REGIME APPLICABLE TO BANKS

Te primary statute governing banks in Korea is the Bank Act. Te Bank Acts generallegislative intent is to help achieve the stability of financial markets and strengthenthe national economy by promoting the sound management of banks, improving theefficiency of financial intermediation, protecting depositors, and generally maintaininga sound credit market. o accomplish these goals, the Bank Act sets forth requirementsfor the establishment and licensing of banks, limitations on control and managementstructures of banks, regulations on banks business operations and a regulatory framework

for the operation of foreign bank branches in Korea.Te banking industry is also subject to a set of supplementary regulations found

in secondary statutes that set forth operational and procedural structures that banksmust adhere to. Te Act on Structural Improvement of Financial Business Industryseeks to promote structural improvement of financial institutions by way of merger,conversion, consolidation, and various other methods. Te Act of Establishment, etc.,of Financial Services Commission establishes supervisory authority in the FinancialServices Commission (FSC) and the Financial Supervisory Service (FSS), the twoadministrative bodies charged with carrying out finance regulation in Korea. TeDepositor Protection Act mandates that some financial institutions participate in adeposit insurance system operated by a government-sponsored corporation known asthe Korea Depositor Insurance Corporation (KDIC). Te Bank of Korea Act sets forthrules concerning the establishment of Koreas central bank, the Bank of Korea (BOK),and the operation of monetary and credit policies.

Te four major administrative bodies engaged in the regulation of financialinstitutions in Korea are the Ministry of Strategy and Finance (MOSF), the BOK,the FSC and the FSS. Te MOSF engages in the establishment of economic policy, the

preparation and execution of the national budget, the establishment and implementationof foreign exchange policy, and the management of the national treasury. Te BOK, asKoreas central bank, pursues price stability and implements monetary policies throughthe Monetary Policy Committee established therein. Te FSCs main role is to integratefinancial policy with financial supervision, and to carry out this role, it oversees thelicensing of Korean financial institutions and administers sanctions to institutions thatare in violation of financial regulations. Another important function of the FSC relates


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to the preparation and enactment of various finance-related laws and regulations andits amendments for the purpose of carrying out its financial policy implementation andfinancial supervision roles. Te FSS operates under the auspices of the FSC, and itsprimary function is the examination and supervision of financial institutions. One of

the proposals made during Park Geun-hyes presidential campaign was the adoptionof a twin peaks regulatory model under which the role of the FSS would be limitedto supervision of financial health and soundness of financial institutions while a newindependent agency would be created to regulate financial consumer protection. If thisproposal is implemented, it will inevitably result in significant changes in the financialregulatory regime in Korea.

When granted a banking licence pursuant to the Bank Act, a bank can generallyengage in most traditional banking operations, including taking deposits, making loans,issuing guarantees and acquiring notes, providing mutual instalment arrangements,investing in, lending, and borrowing securities and packaging or reselling commercial ortrade notes. o conduct foreign exchange business, banks must register with the MOSFpursuant to the Foreign Exchange ransaction Law. Banks must also obtain approval fromthe FSC to engage in credit card business, which is regulated by the Credit SpecialisedFinancial Business Act.

Most financial institutions securities activities are governed by the FinancialInvestment Services and Capital Markets Act (FSCMA). Koreas primary regulatorystatute for the financial investment services industry, the FSCMA, contains licensing

requirements and operational regulations for various securities businesses that banksare often involved in. Tis includes packaging or reselling securities; soliciting investorsfor securities; dealing in government or private debt securities; conducting derivativestransactions; and engaging in trust business. Specifically, the FSCMA contains stringentlicensing requirements for banks or other financial institutions to deal in over-the-counterderivatives, including a capital requirement and minimum institutional standards toensure that such entities are capable of carrying out complex transactions.

Foreign banks that wish to set up a domestic branch within Korea must meetrequirements as set forth in the Bank Act and the Banking Business Regulation issued

by the FSC. Tese requirements generally pertain to a foreign banks good standingwith financial regulators in its home country, the business and operational plans forthe planned Korean branch, and the proposed management and legal structures forthe planned Korean branch. Once established, a domestic branch is subject to similarregulatory supervision as Korean banks.

Many cross-border activities conducted by overseas banks that do not maintain aKorean branch are subject to licensing requirements or other regulatory rules. In general,transactions with a Korean counterparty by overseas banks on a cross-border basis must

be conducted on a reverse inquiry basis and the relevant marketing activities in Koreaor towards Korean residents are restricted.Financial holding companies (FHCs) are regulated business entities that hold and

exercise a controlling interest in financial institutions. Tey are governed by the FinancialHolding Companies Act (FHCA), which limits the scope of FHCs business activitiesto the control of the management of subsidiary units (including the establishment ofbusiness objectives, evaluation of business performance, and determination of corporategovernance structures) and the facilitation of the control of the management of subsidiary


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units (including financing, joint development of financial products and services,and shared use of facilities). FHCs are, subject to a few limited exceptions, expresslyprohibited from engaging in any profit-making businesses other than controlling themanagement of its subsidiaries. FHCs are supervised on a consolidated basis as they

consist of a number of financial units.Corporate governance of banks and their business activities are currently subject

to the Bank Act and its underlying regulations but this may change. If the proposed billsfor the Act on Improving the Corporate Governance Structure of Financial Institutionsand the Act on Protection of Financial Consumers pass the National Assembly, Koreaslegislative body, corporate governance of banks and their business activities as theypertain to consumer protection will be subjected to the newly enacted statutes.

III PRUDENTIAL REGULATION

i Relationship with the prudential regulator

Prudential regulation of banking activity in Korea is carried out by the FSC and theFSS. Banks must comply with prudential regulations regarding capital adequacy, loanloss provisions, credit concentration, liquidity, risk management and internal controls.

Regulatory authorities in Korea generally focus on seeking voluntary complianceby banks through the establishment of their own internal compliance systems. o thisend, all banks must maintain both an audit committee and an independent complianceofficer.

Te FSS sets requirements for both prudent control of liquidity and capital adequacyand establishes reporting requirements within the authority delegated to it under FSCregulations. Pursuant to such regulations, banks are required to submit annual reportson financial performance and shareholdings, regular reports on management strategyand non-performing loans (including write-offs), and management of problematiccustomer companies as well as plans for the settlement of bad loans. Banks must also filemonthly reports detailing their daily foreign exchange positions that are then compared

to position limits. Banks that conduct derivatives transactions are required to submitquarterly reports on derivatives trading activities, and unusual or large derivatives tradingmust be reported monthly.

Te FSSs investigation rights with regard to banks encompass both comprehensiveand partial inspections. Comprehensive inspections, which generally take place every oneto two years, cover the overall business and financial status of a bank. When conducting acomprehensive inspection, regulators evaluate whether internal control and compliancereview systems of the bank are effectively functioning. Partial inspection takes place

when there is a special regulatory need to inspect a particular issue.

Upon completion of an inspection, an inspection report is prepared and deliveredto the bank, and if necessary, the FSS takes corrective measures or imposes sanctionsagainst the bank or its officers and employees. Administrative fines may be imposed forviolations of various regulations, and such violations may result in licence revocation,business suspension, institutional warning or reprimand for the bank or dismissal, salaryreduction, reprimand or warning for its individual officers and employees. Further,


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the violation of some financial regulations may lead to dual penalties as they allow forcriminal prosecution in addition to mere administrative or civil liabilities.

Te FSS also conducts ongoing, regular audits of banks. For each bank, arelationship manager is designated among FSS officials to constantly monitor the business

activities of the bank by reviewing regularly submitted business reports and interviewingofficers and employees of the bank. Te relationship managers job is to discover anddetect managerial weaknesses at each bank. Each year the FSS announces its Plans for

Audit Activities. In 2012, emphasis was put on constant monitoring of potential risks oflarge financial companies for financial stability and tighter control of the foreign currencyliquidity level and one of the main points of the audits included protection of financialcustomers by focusing on financial criminal activities, restrictions of excessive fees andmis-selling. Banks that conduct derivatives transactions must formulate and operate riskmanagement standards against derivatives risks, and the FSC and the FSS require thatbanks set volume limits and stop-loss limits on each dealer or branch at an appropriatelevel in their trading activities of derivatives.

ii Management of banks

Every bank in Korea must maintain a board of directors to manage the bankscorporate governance. Pursuant to the Bank Act, a banks directors must satisfy certainqualifications, including a standard known as the fit-and-proper test, which generallyexamines directors integrity and managerial ability. A banks directors must also possess

demonstrated expertise, experience and knowledge in finance and bank managementand must not pose any harm to the public interest. Te branch manager of a foreignbank is subject to similar requirements, as he or she must possess sufficient managementexpertise, knowledge, and experience specific to bank management, a record of integrityand the ability to fully comply with Korean laws and regulations.

Corporate governance structures for financial institutions have been undergoinglarge-scale transformations in the past decade with the introduction of outside directors,audit committees and compliance officers. Pursuant to an amendment to the Bank Actthat became effective on 18 November 2010, more than 50 per cent of a banks boardof directors must be outside directors and there must be at least three outside directors.Banks are required to establish a recommendation committee for outside directorsthat recommends candidates to be selected and appointed by shareholders at a generalshareholders meeting. In January 2010, regulators presented a Best Practice for OutsideDirectors of Banking Institutions to banks, and banks are now required to examinetheir current outside director system to ensure that this Best Practice is complied with.Compared with the Bank Act and its supplemental supervisory regulations, the BestPractice implements strengthened requirements regarding the qualifications of outside

directors and the implementation of the outside director system.Since 2000, banks have also been required to establish audit committees to operate

under the purview of the board of directors, at least two-thirds of which must consistof outside directors. Banks are also required to appoint compliance officers through aresolution of the board of directors with a two-thirds vote of the board members. Tecompliance officer must be a person of knowledge and expertise in the business of thecompany and remain completely independent in executing his or her duties. Banks must


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respond faithfully to requests for information by the compliance officer in the course andscope of his or her duty.

Corporate governance of financial institutions has been emphasised, in part due tothe recent financial crisis, and the Financial Stability Board has recommended revisions

to the corporate governance structure of financial institutions and compensation forthe management of financial institutions. In response, the FSC submitted a draft billnamed Act on Corporate Governance Structure of Financial Companies to the National

Assembly in June 2012. Tis draft bill includes various measures for enhancing theindependence of the board of directors, including by way of permitting the board todetermine the appointment and dismissal of unregistered executives such as deputygovernors of banks and prohibiting inside directors from participating in the outsidedirector candidate recommendation committee. It also contemplates a risk managementcommittee and compensation committee to address issues relating to risk managementand compensation.

iii Regulatory capital

Te Bank Act contains a minimum legal capital requirement of 100 billion wonfor a nationwide commercial bank. In addition, Korean banking regulators beganimplementing the New Basel Capital Accord, also known as Basel II, in January 2008 tomonitor banks capital adequacy standards. In accordance with these standards, all banksin Korea, whether domestic or foreign, have to determine the size of their risk-weighted

assets based on either a standardised approach or an internal ratings-based approachconsidering their own risk management abilities. Currently, all banks are required tomaintain a minimum capital adequacy ratio of equity capital (defined as ier I and ierII capital, based on the capital standards set by the Basel Committee, less any capitaldeductions) to risk-weighted assets of at least 8 per cent based on credit risk or marketrisk-incorporated criteria.

Furthermore, Korea agreed to introduce a comprehensive set of reformmeasures, developed by the Basel Committee on Banking Supervision, to strengthenthe regulation, supervision and risk management of the banking sector, also knownas Basel III, at the November 2010 G20 Seoul Summit. Te Basel III rules text wasissued by the Basel Committee on 16 December 2010. Basel III places greater focus oncommon equity in regulating the quality and level of capital and introduces a liquiditycoverage ratio restriction and will be gradually implemented in Korea. In order toimplement the minimum capital requirements under Basel III, the FSC amended therelevant regulations. From 2013, the Basel III capital ratio requirements will be subjectto the following minimum requirements: 4.5 per cent for common equity, 6 per centfor ier I capital and 8 per cent for total capital and a more rigid regulated capital

requirement will be implemented. Liquidity regulation (liquidity coverage ratio and netstable funding ratio) and leverage regulation are scheduled to be implemented in 2015and the FSC plans to amend the relevant regulations once the international standard forimplementation is determined. In December 2012, however, the FSC announced that it

will reassess the timing of implementing Basel III after considering what other countriesare doing and the exact timing of the implementation is currently up in the air.


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Under the Bank Act, no bank may expose more than 20 per cent of its totalcapital in loans and credit guarantees to a single individual or corporate borrower. Also, abank may not expose more than 25 per cent of its total capital to an interlinked businessgroup in loans and credit guarantees. Te sum of the credit extended to single individuals

or interlinked business groups that exceeds 10 per cent of the banks total capital must beless than 500 per cent of the banks total capital. Additionally, banks may not invest morethan 60 per cent of their ier I and ier II capital in stocks and other securities with amaturity of more than three years.

Banks are required to maintain a won liquidity ratio, defined as the ratio ofwon-denominated assets with a maturity of less than one month to won-denominatedliabilities with a maturity of less than one month, above 100 per cent. Beginning in

July 2012, banks are required to maintain the ratio of won-denominated assets againstwon-denominated liabilities (i.e., won-reserve ratio) at 100 per cent or lower. For foreigncurrencies, banks must maintain an internal foreign currency liquidity managementsystem based on the maturity ladder approach, and the ratio of liabilities with less thanthree months maturity against assets with less than three months maturity is required tobe at least 85 per cent or greater. In addition, banks are required to maintain a mandatorymaturity non-matching ratio between foreign currency denominated assets and liabilities.However, most of the foreign currency liquidity risk management regulations do notapply to foreign bank branches if its head office has submitted a confirmation letterto the FSS. Also, in evaluating the soundness of bank assets, certain asset classification

criteria apply, and depending on the outcome of such classification, the bank must setaside a certain amount of reserve.

o enforce these standards, regulators check whether banks are in compliancethrough reviews of reports that are submitted by banks on a monthly or quarterly basis.If there exists any risk of non-compliance with relevant requirements, regulators instructthe non-compliant bank to limit an increase in risk assets or increase the amount of itscapital in order to meet the requirements.

In addition, banks are required to make detailed public disclosures regardingtheir compliance with capital adequacy requirements. Trough the public disclosure

requirement, regulators seek to have shareholders, depositors, and other interestedparties actively monitor the appropriateness of banks capital levels.

If a bank fails to meet minimum capital requirements, regulators have theauthority to issue corrective actions, including recommendations, requests, or orders formanagement improvement. Such actions can call for banks to increase capital, limit newinvestment, restrict ownership or dispose of risky assets, or transfer business in whole orpart.

For more severe undercapitalisation or insolvency problems, banking regulators

may request the government or the KDIC to invest in failing banks or otherwisepurchase treasury or public bonds held, or subordinated bonds newly issued, by suchfailing banks. If regulators determine that the interests of depositors could be seriouslyharmed as a result of the bankruptcy or insolvency of a bank, they may take emergencymeasures, such as restricting the bank from taking additional deposits or extendingadditional loans, suspending the deposit-taking business of the bank in whole or in part,or prohibiting discharge of any repayment obligations.


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IV CONDUCT OF BUSINESS

Certain restrictions apply to transactions between banks and their subsidiaries, whichare defined as companies owned 15 per cent or more by a bank. A bank may not extend

credit in excess of 10 per cent of its total capital to any individual subsidiary and in excessof 20 per cent to all of its subsidiaries combined. ransactions with subsidiaries must bemade on an arms-length basis.

Additional restrictions apply when a bank becomes the parent of another bank.Te child bank may not hold any shares in the parent bank or extend any credit tothe parent bank, but the child bank may extend credit to a subsidiary bank subject tomeeting certain collateral reserve requirements. No transaction involving assets classifiedas precautionary may be entered into by and between the parent and child banks.

Privacy laws, such as the Act on Real Name Financial ransactions and Protection

of Secrecy and the Act Concerning Use and Protection of Credit Information, protectagainst disclosure and potential misuse of credit and financial information. Further,the Foreign Exchange ransaction Law provides the necessary protection againstdisclosure of information on foreign exchange transactions. Te Specific Financialransaction Information Report and Usage Act prohibits banks from engaging in moneylaundering. In addition, the Personal Information Protection Act is a general statuteaimed at protecting personal information. Tis statute regulates the overall processing ofpersonal information gathered in either the public or private sectors and is not limited tofinancial institutions. However, other similar data protection statutes will be applicableif separately stated as such in the relevant statute.

Under Korean law, a bank may only possess real estate property for the purposesof conducting its business, and even in such cases the aggregate value of such propertycannot exceed 60 per cent of its ier I and ier II capitals. Further, subject to someexceptions, a bank may not own more than 15 per cent of outstanding voting shares ofanother company.

V FUNDING

Te main sources of funds for commercial banks in Korea are deposits in domesticcurrency, which account for about 55 per cent of banks funding, and bonds, whichaccount for about 10 per cent (as of the end of September 2012). Te primary uses ofthese funds are lending in domestic currency, which accounts for approximately 59 percent of bank spending, and securities investments, which account for approximately 16per cent of bank spending (as of the end of September 2012).

VI CONTROL OF BANKS AND TRANSFERS OF BANKINGBUSINESS

i Control regime

Under the Bank Act, no person or entity, other than the Korean government or theKDIC, may own more than 10 per cent of a banks total issued and outstanding votingshares. Prior approval may be granted by the FSC for any person or entity intending to


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hold in excess of 10 per cent, and such approval requirements are also triggered whenpersons or entities seek to hold in excess of 25 per cent and 33 per cent of a banks totalissued and outstanding voting shares. o obtain such approval, an applicant must meetcertain criteria concerning financial soundness and shareholder qualification as well as

other requirements that vary according to who the applicant is (a Korean corporationor financial institution, a Korean individual, a foreign individual, a private equity fund,etc.).

In particular, a foreign entity intending to hold bank shares in excess of establishedownership limits must meet additional criteria under the Bank Act. First, the entitymust be a company engaged in a financial business in its home country or must be aholding company of such a financial company. Also, the entity must be fit to operateinternational business based on its asset size and business scope and must be globallyreputable. Te foreign applicant must not have been subject to any serious regulatorysanctions in its home country and must have maintained a BIS capital ratio of at least 8per cent for the three years prior to its application.

Korean law also has special ownership requirements for non-financial businessoperators (NFBOs). An investor and its affiliate companies, as a whole, are deemed toconstitute an NFBO if the aggregate gross capital of the investors non-financial affiliatescompanies (including the investor itself, if applicable) is 25 per cent or more of theaggregate gross capital of such investor and its affiliate companies; or the aggregate assetvalue of the investors non-financial affiliate companies (including the investor itself, if

applicable) is 2 trillion won or more. Following amendments to the Bank Act and FHCAenacted in 2009, the percentage of voting shares of a bank or bank holding company thatmay be owned by an NFBO has increased from 4 per cent to 9 per cent. If an NFBOacquires ownership interest in a bank or bank holding company in excess of 4 per cent,it must still obtain FSC approval if it is either the largest shareholder or participates inmanagement.

A banks major shareholders are defined as shareholders who hold a 10 per centequity interest in a bank, or who hold a 4 per cent equity interest in a bank as its largestshareholder, or who exercise management control over a bank or NFBOs that hold more

than 4 per cent equity interest in a bank and is participating in the management of thebank. Tere are no provisions under Korean banking law imposing sanctions againstmajor shareholders of an insolvent bank, but such major shareholders are prohibitedfrom becoming major shareholders of other financial institutions, including other banks,for five years subsequent to the banks insolvency.

o obtain the regulatory approval necessary to own more than a 10 per centequity stake in a bank, an applicant must meet certain criteria concerning financialsoundness and shareholder qualification depending on what type of individual or entity

it is. Financial institutions seeking to acquire control of a banking business must alsofile a business combination report with the Fair rade Commission of Korea and receiveregulatory clearance. If the acquirer is a foreign entity, a foreign investment report mustalso be filed pursuant to the Foreign Investment Promotion Law. In addition, variousother disclosure requirements triggered by a change of major shareholders must becomplied with. If the bank is a listed company, certain filing requirements are triggeredunder the FSCMA.


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Furthermore, a bank is prohibited from extending a loan to a major shareholderthat amounts to 25 per cent of the banks total capital or the amount equal to theinvestment ratio of the major shareholder in the bank (i.e., investment ratio multiplied byown capital), whichever is less. In addition, the total amount of loans extended to major

shareholders must not exceed 25 per cent of a banks total capital. Tese provisions applynot only to major shareholders but also to persons specially related to major shareholders,defined as persons connected to a major shareholder through either ownership of 30 percent or more of the major shareholders equity interests or the ability to control the majorshareholders management.

A bank must not acquire any shares issued by a major shareholder (includingpersons specially related to a major shareholder) in excess of 1 per cent of the banks totalcapital, and must obtain advance approval from its board of directors in order to acquireshares in excess of 0.1 per cent of the banks equity capital or 5 billion won, whichever isless. Banks must also obtain unanimous board approval in order to extend loans to majorshareholders (including persons specially related to a major shareholder) in excess of 0.1per cent of the banks equity capital or 5 billion won, whichever is less. In such situations,the bank in question must also promptly make a public disclosure detailing such activity.

A major shareholder (including persons specially related to a major shareholder)may not, in pursuit of its own interests, request confidential information regardingits bank or exercise unfair influence over the management of the bank that conflicts

with the banks interests. Te FSS has the authority to conduct an examination of the

business matters and asset ownership status of the major shareholder if it suspects thatinappropriate pressure has been wielded by the major shareholder in the managementof the bank and the FSC may impose monetary penalties on the major shareholder thatexercise such inappropriate influence.

A bank owned by an FHC is prohibited from extending credit to parent FHC andfrom holding shares in FHC affiliates. Such banks are also prohibited from extendingcredit in excess of 10 per cent of their total capital to individual FHC affiliates and inexcess of 20 per cent of their total capital to all FHC affiliates combined.

Large conglomerates increasing their influence over banks has been the subject of

significant criticism recently. It is anticipated that the regulations aimed at the separationof banking and commerce that were eased during the Lee Myungbak administration

will be strengthened. Amendment bills for the Bank Act and the Financial HoldingCompany Act reflecting this policy change (including restoring the shareholding limiton banks and bank holding companies by industrial capital from the current 9 per centto 4 per cent) have already been submitted to the National Assembly.

ii Transfers of banking business

In the case of a transfer by the transferor bank of all or part of its business to a transfereebank, an application for approval of such transfer must be submitted collectively by thetransferor and transferee and a prior approval from FSC is required for such transfer totake place. Tis business transfer is conducted pursuant to the procedures set forth in theBank Act and the Korean Commercial Code and in principle requires the approval ofthe shareholders of both the transferor bank and the transferee bank. Unlike in a mergersituation, the relevant transfer process for each particular asset that is being subjected


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to the business transfer (e.g., loan arrangements and deposit liabilities, real property,labour contracts and other relevant contractual arrangements) must be consummated.However, mergers and business transfers are similar in that both require the submissionof corporate combination reports to the Korea Fair rade Commission.

VII THE YEAR IN REVIEW

i Financial Consumer Protection

Protection of financial consumers has become a worldwide trend and Korea is no exception.In 2012, financial consumer protection organisations initiated lawsuits regarding themortgage fees charged by financial institutions and the Korean regulators have beenemphasising consumer protection in their bank audits and from a policy perspective

as well. A draft bill (tentatively titled Act on Protection of Financial Consumers) wassubmitted to the National Assembly in 2012 and there have been discussions in the marketand academia about the need for stronger consumer protection regulation through theestablishment of a dedicated financial consumer protection agency. Te policy emphasison financial consumer protection is expected to continue and the regulators are expectedto focus on unfair practices and business activities of banks.

ii Privatisation of Woori Bank and Korea Development Bank

Te Korean government holds a controlling stake in the Woori Bank financial holdingcompany (Woori Holdco) and 100 per cent of the Korea Development Bank financialholding company (KDB Holdco). Various efforts were undertaken in 2012 to privatiseboth Woori Holdco (through a public auction) and KDB Holdco (through an IPO ofKDB Holdco) but such efforts all fell through due to unfavourable market conditions.

Due to the general consensus that it is inappropriate for the government to holda controlling stake in Woori Holdco, which is ultimately a private financial institution,the government is expected to resume the sale process when market conditions settle.One of the election promises of President Park Geun-hye was to spin off a local bank

subsidiary of Woori Holdco and further discussions regarding the sale are expected. Tenew administration is also expected to re-examine the privatisation of KDB Holdco andreassess the role of policy-oriented financial institutions and this could lead to significantchanges in whether KDB Holdco will in fact be privatised and its role.

iii Strengthened regulation of bank ownership

As discussed above, amendment bills for the Bank Act and the Financial HoldingCompany Act aiming to implement the separation of banking and commerce policy

change have been submitted to the National Assembly. Tese bills restore the shareholdinglimit on banks and bank holding companies by industrial capital from the current 9 percent to the previous level of 4 per cent, and make it more difficult for industrial capitalto become limited partners of private equity funds by lowering the limit on total equitycontribution permitted to the private equity fund by limited partners who are industrialcompanies from the current 18 per cent to 10 per cent. Tere have not been any casesin which industrial capital or private equity funds became the major shareholder of aKorean bank; thus, this policy change will likely not have an immediate impact on the


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ownership structure of Korean banks but foreign investors that have invested in Koreanbanks or financial holding companies should be aware of the implications of this policychange on regulations of banks.

VIII OUTLOOK AND CONCLUSIONS

In the course of overcoming the global financial crisis, banks had to increase theircredit exposure to small and medium-sized enterprises, and despite strengthened loan-to-value ratio (LV ratio) and debt-to-income ratio (DI ratio) regulations, banksalso increased mortgaged housing loans to individuals. Regulators are now concernedthat the risks latent in such increased credit exposures may materialise, becoming thenext major destabilising factor in the financial market, and thus are expected to require

banks to implement adequate management plans. Te new President Park Geun-hyeadministration is expected to take a more proactive position in its attempt to solve thehousehold debt problem.

Concerned about the possibility of another financial crisis and the eurozonedebt crisis, the Korean regulators have been recommending limitations on excessivegrowth and increase of reserving profits for prudential regulation purposes. Te Koreanregulatory authorities have introduced a new guideline that enables banks to conducttheir foreign exchange-related business in a more sound and prudent manner. Teguideline changes the calculation method of the foreign currency liquidity ratio that

banks are required to comply with (such that each foreign currency asset is weightedbased on its liquidity level) and requires that banks prepare and implement internalcontrol standards including stress tests assuming emergency situations.

Te MOSF introduced new ceilings on FX derivatives positions on 9 July 2010and such ceilings have been revised twice since introduction due to the increased volatilityin the foreign currency market resulting from the rapid surge in foreign currency inflow.Tis situation also led to the following amendments to the FX regulations. On 12 July2010, the BOK released a guideline including details of the new regulations such ascalculation of FX derivatives positions, scope of the regulations and exceptions. Tere arecertain exceptions (e.g., if it is necessary to stabilise the foreign exchange market) but thisguideline in principle states that the ceilings on domestic banks FX derivatives contracts

will be no more than 50 per cent of their capital based on their daily moving average forthe previous 30 days and, in the case of foreign bank branches, FX derivatives positionscannot exceed 250 per cent of their capital. he position limits of 50 per cent and 250per cent were changed to 40 per cent and 200 per cent, respectively, in 1 July 2011 and

were further revised to 30 per cent and 150 per cent, respectively, from 1 January 2013.Te regulatory authorities also required banks to remedy their compensation

system based on short-term performance, which has been criticised as one of the factorsthat triggered the global financial crisis by causing banks to take excessive risk in theirinvestment decisions. In response, the regulators presented to banks on 20 January 2010a Best Practice for Compensation System based on the principles and standards proposedby the Financial Stability Board of the G20.

Te Korean regulatory authorities have also been emphasising consumerprotection, as evidenced by the broadened disclosure requirement of bank fees and


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strengthened regulation on preventing mis-selling activities. In this regard, the FSCsubmitted an overarching statute that covers all stages of financial consumer activities(i.e., the Financial Consumer Protection Act) in July 2012.

Te new President Park Geun-hye administration launched in February 2013

and we expect some changes to the financial policy of the government. Protection offinancial consumers was an important election pledge of President Park Geun-hye butderegulation of the financial industry has not been a prominent proposition. Lookingahead, the major issues in Korean banking regulation will be the progress of PresidentParks commitment to protection of financial consumers and the need to enhance thecompetitiveness of the financial industry. Interestingly, the two goals are to some extentat odds with one another, especially in the short term. How the tension between thesetwo goals is resolved will be crucial, as this will have a long-term impact on both theKorean and East Asian economies.


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Appendix 1

ABOUT THE AUTHORS

SANG HWAN LEE

Kim & Chang

Sang Hwan Lee is a senior attorney in the firms banking, securities regulations,investment management, Japanese and derivatives practice groups.

Mr Lee practises in a wide range of areas of finance-related law, with a focus onbanking laws and regulations and mergers and acquisitions of financial institutions. Healso has extensive experience advising clients in financial derivatives transactions andcorporate finance matters. As a member of the Japanese practice group, Mr Lee alsoadvises a broad range of Japanese financial institutions. Mr Lees representative works inrecent years include advising on major mergers and acquisitions of domestic banks andpost-transaction integration of banks and representing financial institutions investigatedby the Financial Supervisory Service. Mr Lee has also acted as an outside adviser to the

Ministry of Finance and Economy as a member of the ministrys Financial IndustryDeliberation Committee and as a member of the ministrys Task Force for Improvementof Credit Information System.

Mr Lee received his BA in law from Seoul National University and his LLM fromCornell Law School. He is admitted to practise in Korea and New York.

CHAN MOON PARK

Kim & Chang

Chan Moon Park is a senior attorney in the firms banking, capital markets, project

finance, securities regulations and structured finance practice groups.Since joining Kim & Chang in 1998, Mr Park has worked in diverse areas

including M&A in the financial industry, banking and securities regulations, asset-backed securitisation, project financing, international capital markets and tax.

Mr Park received his BA in law from Seoul National University and his LLMfrom Duke University Law School. He is a member of the Bar of the Republic of Korea.


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About the Authors

SANG HWAN LEE

Kim & Chang

Sang Hwan Lee is a senior attorney in the firms banking, securities regulations,investment management, Japanese and derivatives practice groups.

Mr Lee practises in a wide range of areas of finance-related law, with a focus onbanking laws and regulations and mergers and acquisitions of financial institutions. Healso has extensive experience advising clients in financial derivatives transactions andcorporate finance matters. As a member of the Japanese practice group, Mr Lee alsoadvises a broad range of Japanese financial institutions. Mr Lees representative works inrecent years include advising on major mergers and acquisitions of domestic banks andpost-transaction integration of banks and representing financial institutions investigatedby the Financial Supervisory Service. Mr Lee has also acted as an outside adviser to the

Ministry of Finance and Economy as a member of the ministrys Financial IndustryDeliberation Committee and as a member of the ministrys Task Force for Improvementof Credit Information System.

Mr Lee received his BA in law from Seoul National University and his LLM fromCornell Law School. He is admitted to practise in Korea and New York.

KIM & CHANG

Seyang Building

223 Naeja-dong, Jongno-guSeoul 110-720KoreaTel: +82 2 3703 1114Fax: +82 2 737 9091/[email protected]@[email protected]

www.kimchang.com

Documents

13 Banking Regulation Review - Korea