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The Implications of South Korea’s Placement on the US DOE’s Sensitive Country List

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The Implications of South Korea’s Placement on the US DOE’s Sensitive Country List

South Korea is the only U.S. ally on the list. What will it mean for the relationship, and for South Korea?

The Implications of South Korea’s Placement on the US DOE’s Sensitive Country List
Credit: ROK Ministry of Foreign Affairs

Despite intense lobbying from the South Korean government to reverse a preliminary decision, the United States recently placed South Korea on the Department of Energy’s (DOE) Sensitive Country List. The decision has sparked concerns in South Korea about potential limitations on collaboration on energy, artificial intelligence (AI), and other cutting-edge technologies, and the reputational damage from South Korea being the only U.S. ally on the Sensitive Country List.

The Sensitive Country List is designed to provide additional scrutiny over access by foreign nationals to U.S. research facilities, to ensure that sensitive information is not accidentally transferred. Countries can be added to the list for reasons related to national security, nuclear nonproliferation, or their support for terrorism. The list includes U.S. adversaries such as China, Iran, Russia, and North Korea, but also non-allied U.S. partners such as Israel, India, and Taiwan. South Korea was added to the “other designated countries” portion of the list, the lowest level of designation

The exact reason for South Korea’s placement on the Sensitive Country List is unclear, but the process began at the end of the Biden administration. U.S. Chargé d’Affaires Joseph Yun has suggested that South Korea was included due to the mishandling of some sensitive information by South Korean nationals, something that seems to have been confirmed by information provided in a DOE audit submitted to Congress last year. The DOE noted that a contractor had been fired after they tried to take nuclear reactor design software to South Korea from the Idaho National Laboratory. The report also indicated that the individual had been in communication with a foreign government

Generally, a country would not be added to the Sensitive Country List for a single violation. Rather, the individual or others from their home institution would be prohibited from visiting sensitive U.S. facilities. South Korean officials have confirmed that the designation was not due to a single incident, nor was it due to foreign policy concerns related to South Korea or the political situation stemming from former President Yoon Suk-yeol’s attempt to impose martial law in December 2024. However, the U.S. government has not provided a full detailing of the security violations that resulted in South Korea being placed on the Sensitive Country List.

While a DOE spokesperson indicated that South Korea’s placement will not preclude collaboration between scientists or scientific or technological cooperation between the two countries, increased screening will be required before any such collaboration. South Koreans will now need to go through an approval process 45 days prior to visiting a U.S. national laboratory, while DOE staff and related researchers will be subject to greater scrutiny of their travel to and communication with South Korean officials and researchers.

Despite assurances that South Korea’s inclusion on the Sensitive Country List will not impact ongoing cooperation, there are concerns that there could still be limitations. For example, projects such as DOE’s Predictive Science Academic Alliance Program require that participants be either U.S. citizens or from countries not on the Sensitive Country List.

South Korea could also face follow on policy difficulties from inclusion on the Sensitive Country List. The Export Control Reform Act of 2018 established an inter-agency process overseen by the Commerce Department that includes the departments of Energy, State, and Defense, and other agencies. Because of efforts to create a coordinated approach to export controls, the DOE restrictions could impact nuclear cooperation with other parts of the U.S. government. 

It may also impact future policy objectives. South Korea has long sought the ability to reprocess spent nuclear fuel, but the United States has limited cooperation on reprocessing spent nuclear fuel to a pilot project on pyroprocessing, a high temperature and chemical form of reprocessing spent nuclear fuel. U.S. acquiescence to South Korean reprocessing of spent nuclear fuel or the enrichment of uranium, another pathway to a nuclear weapon, is less likely with South Korea now on the Sensitive County List. More immediately, the designation could be used as a tool by the Trump administration to leverage additional concessions from South Korea on trade as part of talks over the new U.S. tariffs.

Removing South Korea from the Sensitive Country list will take time. It will now be subject to an annual review and need to go through DOE procedures to be removed from the Sensitive Country List. This is not the first time South Korea was on the Sensitive Country list. South Korea was originally placed on the list in 1981, though Seoul did not learn of its inclusion until 1993. It was able to achieve removal in 1994.