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jhan@cgsh.com

 August 14, 2024

VIA EDGAR

 Mr. Thomas Kluck

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 Office of International Corporate Finance

 100 F
Street, NE

 Washington, D.C. 20549

Re:
 The Export-Import Bank of Korea

 
 The Republic of Korea

 
 Registration Statement under Schedule B

 
 File No. 333-280523

 
 Filed on June 27, 2024

Dear Mr. Kluck:

 On behalf of our clients,
The Export-Import Bank of Korea (“KEXIM”) and The Republic of Korea (the “Republic” and, together with KEXIM, the “Registrants”), we set forth below the Registrants’ responses to your letter,
dated July 24, 2024, containing the comment of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Registrants’ registration statement under
Schedule B (File No. 333-280523) (the “Registration Statement”) filed with the Commission on June 27, 2024. For your convenience, we have reproduced below the Staff’s comments
and have provided the Registrants’ responses immediately below each of the comments.

 The Registrants plan to file Amendment
No. 1 to the Registration Statement (“Amendment No. 1”) in response to some of the Staff’s comments.

Selected Financial Statement Data, page 7

1.
 You state on page 8 that the net gain (loss) on hedging derivative assets moved to a net gain of Korean won
2,013 billion in 2023 from a net loss of Korean won 3,224 billion in 2022 due to a decrease in losses on hedging instruments to Korean won 843 billion in 2023 from Korean won
3,716 billion in 2022 and an increase in gains on hedging instruments to Korean won 2,856 billion in 2023 from Korean won 492 billion in 2022, which in turn was primarily due to increased
volatility in exchange rates and interest rates in 2023. Please tell us and revise your disclosure as appropriate to discuss the primary currencies and interest rates that drove the volatility from period to period and provide quantitative
information to explain how the volatility in those factors drove the material fluctuations in earnings from year to year.

 Cleary Gottlieb Steen
& Hamilton LLP or an affiliated entity has an office in each of the locations listed above.

 Mr. Thomas Kluck

August 14, 2024

  p.
 2

 2022

The currencies that had the largest impact on the volatility in exchange rates in 2022 were the Brazilian Real (“BRL”) on the buy side and the
United States Dollar (“USD”) on the sell side. The interest rates that had the largest impact on the volatility in interest rates in 2022 were the Australia 3-Month Bank Bill Swap Rate (the
“AUD 3M BBSW”) on the buy side and the United States Dollar 3-Month London Interbank Offered Rate (the “USD 3M LIBOR”) and the Secured Overnight Financing Rate (the
“SOFR”) on the sell side. A numerical presentation of the changes in exchange rates and interest rates from 2021 to 2022, and the resulting effect on KEXIM’s gains/losses on hedging instruments in 2022, are as shown below:

As of December 31,
2021

As of December 31,
2022

Percentage Change

Effect on gains/(losses) on
hedging derivatives in 2022

(Korean Won or percentage, as applicable)

(%)

(in billions of Korean Won)

 Exchange Rates(1):

 1 Brazilian Real (BRL)

W
212.77

W
239.72

12.7
%

W
249

 1 United States Dollar (USD)

W
1,185.50

W
1,267.30

6.9
%

W
(956
)

 Interest Rates:

 AUD 3M BBSW

0.05
%

3.06
%

6,456.7
%

W
45

 USD 3M LIBOR

0.21
%

4.77
%

2,179.6
%

W
(958
)

 SOFR

0.05
%

4.30
%

8,500.0
%

W
(108
)

 Other(2):

— 

— 

— 

W
(1,495
)

 Total

— 

— 

— 

W
(3,224
)

(1)
 Converted to Won amounts at the market average exchange rates in effect on December 31, 2021 and 2022, as
applicable, as announced by Seoul Money Brokerage Services, Ltd.

(2)
 Includes all other exchange rates and interest rates, as well as gains and losses resulting from daily
settlements made by clearing houses.

 2023

The currencies that had the largest impact on the volatility in exchange rates in 2023 were BRL, the Swiss Franc (“CHF”), the Euro
(“EUR”) and the Australian Dollar (“AUD”) on the buy side and USD on the sell side. The interest rates that had the largest impact on the volatility in interest rates in 2023 were AUD 3M BBSW on the buy side and USD
3M LIBOR and SOFR on the sell side. A numerical presentation of the changes in exchange rates and interest rates from 2022 to 2023, and the resulting effect on KEXIM’s gains/losses on hedging instruments in 2023, are as shown below:

As of December 31,
2022

As of December 31,
2023

Percentage Change

Effect on gains/(losses) on
hedging derivatives in 2023

(Korean Won or percentage, as applicable)

(%)

(in billions of Korean Won)

 Exchange Rates(1):

 1 Brazilian Real (BRL)

W
239.72

W
265.72

10.9
%

W
346

 1 Swiss Franc (CHF)

W
1,372.87

W
1,526.82

11.2
%

W
169

 1 Euro (EUR)

W
1,351.20

W
1,426.59

5.6
%

W
100

 1 Australian Dollar (AUD)

W
858.41

W
880.08

2.5
%

W
84

 1 United States Dollar (USD)

W
1,267.30

W
1,289.40

1.7
%

W
(276
)

 Interest Rates:

 AUD 3M BBSW

3.06
%

4.31
%

41.0
%

W
24

 USD 3M LIBOR

4.77
%

5.59
%

17.3
%

W
(135
)

 SOFR

4.30
%

5.38
%

25.1
%

W
(81
)

 Other(2):

— 

— 

— 

W
1,784

 Total

— 

— 

— 

W
2,013

(1)
 Converted to Won amounts at the market average exchange rates in effect on December 31, 2022 and
December 29, 2023, as applicable, as announced by Seoul Money Brokerage Services, Ltd.

(2)
 Includes all other exchange rates and interest rates, as well as gains and losses resulting from daily
settlements made by clearing houses.

 Mr. Thomas Kluck

August 14, 2024

  p.
 3

 The Registrants respectfully acknowledge the Staff’s comment and advise the Staff that they plan to
revise the relevant paragraph on page 8 of the Registration Statement, through Amendment No. 1, as follows, and to provide a similar level of disclosure where relevant in the Registrants’ future filings:

We had net income of W723 billion in 2023 compared to W387 billion in 2022. The principal
factors for the increase in net income included:

•  a change in net gain (loss) on hedging derivative assets to a net gain of
W2,013 billion in 2023 from a net loss of W3,224 billion in 2022, due to a decrease in losses on hedging instruments to W843 billion in 2023 from W3,716 billion
in 2022 and an increase in gains on hedging instruments to W2,856 billion in 2023 from W492 billion in 2022, which in turn was primarily due to increasedcontinued volatility in exchange rates (including USD and BRL) and interest
rates (including the USD 3-Month London Interbank Offered Rate, the Secured Overnight Financing Rate and the Australia 3-Month Bank Bill Swap Rate) in 2023;

2.
 You state on page 8 that the net gain (loss) on financial assets at fair value through profit or loss moved
to a net gain of Korean won 210 billion in 2023 from a net loss of Korean won 306 billion in 2022, primarily due to a change in valuation of trading derivatives to a net gain of Korean won
56 billion in 2023 from a net loss of Korean won 764 billion in 2022. Please tell us and revise your disclosure as appropriate to discuss the primary types of trading derivatives that drove the changes in fair
value, and discuss the factors driving the change, including, as applicable, the currency or interest rates and quantification of how those rates changed to impact the valuations from year to year.

The primary types of trading derivatives that drove the changes in the valuation of trading derivatives between 2022 and 2023 were cross-currency swaps
(“CCSs”), which are more commonly known in Korea as currency-interest rate swaps. A CCS is a derivative product in the form of an agreement between two parties to exchange interest and principal payments denominated in one currency
for agreed amounts in another currency, using floating and/or fixed rates of interest, in essence combining the features of both a currency swap and an interest rate swap. In its ordinary course of business, KEXIM frequently enters into CCS
derivative transactions for trading purposes or to secure certain amounts of foreign currencies to hold.

 The Registrants respectfully submit that it is
not feasible to quantify the impact the changes in specific exchange rates and interest rates have had on the valuations of its CCSs from 2022 to 2023, primarily due to the sheer volume of CCS transactions that KEXIM enters into in any given year.
To elaborate, unlike other financial institutions that deal in a handful of major foreign currencies and interest rates, KEXIM deals in hundreds of various foreign currencies and interest rates in any given year in order to meet the various demands
of its export-import businesses. As a result, the effects of any changes in exchange rates or interest rates are dispersed across many foreign currencies and interest rates, often in small amounts that vary from period to period, which makes it
difficult for KEXIM to point to specific factors that resulted in the changes in the valuation of its CCSs between 2022 and 2023. Instead, a numerical presentation of the changes in those exchange rates and interest rates which KEXIM believes to
have had a significant impact on the valuation of its CCSs due to the fluctuations in such rates between 2022 and 2023, is as shown below:

As of December 31,
2022

As of December 31,
2023

Percentage Change

(Korean Won or percentage, as applicable)

 Exchange Rates(1):

 1 Mexican Peso (MXN)

W
65.06

W
75.98

16.8
%

 1 United States Dollar (USD)

W
1,267.30

W
1,289.40

1.7
%

 1 Swiss Franc (CHF)

W
1,372.87

W
1,526.82

11.2
%

 1 Euro (EUR)

W
1,351.20

W
1,426.59

5.6
%

 Interest Rates:

 USD 3M LIBOR

4.77
%

5.59
%

17.3
%

 MXN TIIE 28D

10.53
%

11.50
%

9.2
%

(1)
 Converted to Won amounts at the market average exchange rates in effect on December 31, 2022 and
December 29, 2023, as applicable, as announced by Seoul Money Brokerage Services, Ltd.

 Mr. Thomas Kluck

August 14, 2024

  p.
 4

 The Registrants respectfully acknowledge the Staff’s comment and advise the Staff that they plan to
revise the relevant paragraph on page 8 of the Registration Statement, through Amendment No. 1, as follows, and to provide a similar level of disclosure where relevant in the Registrants’ future filings:

We had net income of W723 billion in 2023 compared to W387 billion in 2022. The principal
factors for the increase in net income included: . . .

•  a change in net gain (loss) on financial assets at fair value through profit or loss to a net gain
of W210 billion in 2023 from a net loss of W306 billion in 2022, primarily due to a change in valuation of trading derivatives to a net gain of W56 billion in 2023 from a net loss of
W764 billion in 2022, which in turn resulted mainly from changes in exchange rates and interest rates between 2022 and 2023 that impacted the
valuation of our various cross-currency swap derivative products in 2023; and

3.
 We note your disclosure on page 9 that, “As of December 31, 2022, our total
liabilities increased by 23.9% to W106,634 billion from W86,099 billion as of December 31, 2021, primarily due to a
14.8% increase in debentures to W87,792 billion as of December 31, 2022 from W76,486 billion as of
December 31, 2021 and an 81.3% increase in borrowings to W10,113 billion as of December 31, 2022 from
W5,577 billion as of December 31, 2021.” Please provide a more detailed analysis as to why there was an increase in debentures and borrowings in 2022.

 KEXIM’s two primary sources of funding are debentures, mostly through the issuance of bonds in both domestic and international
capital markets, and borrowings from domestic and foreign financial institutions. KEXIM’s debentures and borrowings increased from 2021 to 2022, primarily due to KEXIM’s preemptive measures to obtain financing in light of adverse global
market conditions and an increase in demand for funding from Korean companies, which led KEXIM to issue large amounts of debt securities, increase its long-term borrowings and actively utilize commercial paper for short-term financing during 2022.

 During the course of 2022, KEXIM engaged in certain preemptive measures to obtain financing in light of adverse signs in the global financial markets,
including the tightening of monetary policies by central governments, including the U.S. Federal Reserve, and geopolitical risks, including those stemming from the conflict involving Ukraine and Russia, as well as disruptions in the global supply
chain for raw materials, among others. These factors prompted KEXIM to actively issue long-term debentures while interest rates were still relatively low in the international capital markets, for example, by conducting its largest ever debt offering
in the aggregate principal amount USD 3 billion in January 2022, and issuing debt securities in various other currencies, including the Australian dollar in the aggregate principal amount of AUD 650 million and Euro in the aggregate
principal amount of EUR 1.5 billion, throughout 2022. KEXIM’s need for financing also stemmed from the need to meet increased demand for funding from Korean companies in light of a progressively adverse business environment in 2022,
including as a result of disruptions in the global supply chain for raw materials and rising inflationary pressures, among others. Some of the key funding needs also came from Korean exporters in need of financing to promote key areas related to K-New Deal, a government initiative first announced in July 2021 to re-invigorate the Korean economy, including wind and solar power, secondary batteries and energy storage
systems, and next-generation semi-conductors, among others. Finally, significantly increased demand came from ESG financing in the form of green, social and/or sustainability bonds and loans whose use of proceeds would be dedicated to certain
projects fulfilling certain environmental or social mandate.

 Mr. Thomas Kluck

August 14, 2024

  p.
 5

 The Registrants respectfully acknowledge the Staff’s comment and advise the Staff that they plan to
revise the relevant paragraph on page 9 of the Registration Statement, through Amendment No. 1, as follows, and to provide a similar level of disclosure where relevant in the Registrants’ future filings:

As of December 31, 2022, our total liabilities increased by 23.9% to W106,634 billion from
W86,099 billion as of December 31, 2021, primarily due to a 14.8% increase in debentures to W87,792 billion as of December 31, 2022 from W76,486 billion as of
December 31, 2021 and an 81.3% increase in borrowings to W10,113 billion as of December 31, 2022 from W5,577 billion as of December 31,
2021, which increases were mainly attributable to our preemptive measures to obtain financing in light of adverse global market conditions and an increase in demand for
funding from our borrowers.

 Financial Statements

Note 20 – Derivatives, page 108

4.
 We note your disclosure on page 56 that the gain or loss from remeasuring the hedging instrument at fair
value for a derivative hedging instrument and the gain or loss on the hedged item attributable to the hedged risk are recognized in profit or loss in the same line item of the separate statement of comprehensive income. However, we also note your
disclosure on page 110 in footnote (4) that shows the gain or loss on the fair value hedge – hedging instruments of Korean won (in millions) of 2,013,401 and (3,229,844) for the years ended December 31,
2023 and 2022, respectively, which appears to be the same or similar to the amount reported on “net gain (loss) on hedging derivative assets” line i