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CORRESP

AMERICAS

One Liberty Plaza

EUROPE & MIDDLE EAST

NEW YORK

New York, NY 10006-1470

ABU DHABI

SAN FRANCISCO

T: +1 212 225 2000

BRUSSELS

SÃO PAULO

F: +1 212 225 3999

COLOGNE

SILICON VALLEY

FRANKFURT

WASHINGTON, D.C.

clearygottlieb.com

LONDON

MILAN

ASIA

PARIS

BEIJING

ROME

HONG KONG

D: +82 2 6353 8020

SEOUL

jhan@cgsh.com

 August 26, 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 the oral
comments we received on August 19, 2024 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on our response letter filed with the Commission on August 14, 2024,
which in turn was prepared in response to the Staff’s comments we initially received on July 24, 2024 relating 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 summarized below the Staff’s oral comments and have
provided the Registrants’ responses immediately below each of the comments.

 With this letter, the Registrants are filing Amendment
No. 1 to the Registration Statement (“Amendment No. 1”) in response to some of the Staff’s comments we received.

1.
 Please explain in greater detail the reasons or drivers for the 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.

Trading Derivatives

The Registrants respectfully inform the Staff that KEXIM utilizes its derivative instruments primarily to hedge most of its
exposures to fluctuations in various foreign currencies and interest rates, to the extent feasible. These instruments include interest rate swaps (“IRSs”) and cross currency swaps (“CCSs”), some of which KEXIM
classifies as trading derivatives, rather than as hedging derivatives based on application of the hedging accounting method.

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

 Mr. Thomas Kluck

August 26, 2024

  p.
 2

 For example, KEXIM enters into IRSs in order to hedge the risk of differences
between its interest income received on loan assets based on floating rates and its interest expenses paid on debentures issued at fixed rates. On initial designation, these IRSs would be classified either as hedging derivatives if a hedging
relationship has been established, or as trading derivatives if a hedging relationship does not exist. If KEXIM later determines that a hedging relationship is no longer valid for any hedging derivative, KEXIM would discontinue classifying such
derivative as a hedging derivative and would instead designate it as a trading derivative.

 KEXIM also enters into IRSs in
relation to its project finance (“PF”) loan assets, which usually entail floating rates of interest, as the borrowers generally wish to lock in their payment obligations at a fixed rate given the typically long maturity period. In
such cases, KEXIM enters into IRSs with the borrowers to receive fixed rates of interest, which are classified as trading derivatives, and KEXIM then enters into
back-to-back reverse IRSs in the market (usually with third party financial institutions) to send out fixed rates of interest received pursuant to the first IRS for
floating rates of interest in order to hedge its own risk arising from the initial IRS that it entered into with the borrower of the PF loan assets. These reverse IRSs are also classified as trading derivatives.

The Registrants, in order to provide the Staff with a better understanding of the factors that had a large impact on the
valuations of trading derivatives in 2022 and 2023, have prepared the breakdowns shown below.

 2022

The main factors that contributed the most to the changes in the fair value of KEXIM’s trading derivatives in 2022 were as
follows:

•

 IRSs using floating rates on the sell side paired with fixed rates on the buy side, which were mainly in the
following currencies: the U.S. Dollar (“USD”) (USD SOFR ON or USD 3M/6M LIBOR), the Australian Dollar (“AUD”) (AUD 3M BBSYB), and the British Pound (GBP SONIA ON and GBP 6M LIBOR);

•

 CCSs using fixed rates in Euro or the Korean Won (“KRW”) on the buy side paired with fixed rates
in USD on the sell side;

•

 CCSs using floating rates in the Mexican Peso (“MXN”) (MXN TIIE 28D) on the buy side paired with
fixed rates in USD on the sell side;

•

 CCSs using floating rates in AUD (AUD 3M BBSW) on the buy side paired with floating rates in USD (USD 3M LIBOR)
on the sell side; and

•

 CCSs using floating rates in USD (USD 3M LIBOR) on the sell side paired with fixed rates in KRW on the buy side.

 Mr. Thomas Kluck

August 26, 2024

  p.
 3

 A numerical presentation of the changes in exchange rates and interest rates
mentioned above from 2021 to 2022 are as shown below:

As of December 31,
2021

As of December 31,
2022

Percentage Change

(Korean Won or percentage, as applicable)

 Exchange Rates(1):

 1 U.S. Dollar (USD)

W
1,185.50

W
1,267.30

12.33
%

 1 Australian Dollar (AUD)

W
858.89

W
858.41

(0.06
)%

 1 British Pound (GBP)

W
1,600.25

W
1,527.67

(4.54
)%

 1 Euro (EUR)

W
1,342.34

W
1,351.20

0.66
%

 1 Mexican Peso (MXN)

W
57.92

W
65.06

12.33
%

 Interest Rates:

 USD SOFR ON

0.05
%

4.30
%

8,500.00
%

 USD 3M LIOR

0.21
%

4.77
%

2,179.58
%

 USD 6M LIBOR

0.34
%

5.14
%

1,398.82
%

 AUD 3M BBSW

0.05
%

3.06
%

6,456.67
%

 GBP SONIA ON

0.19
%

3.43
%

1,698.27
%

 GBP 6M LIBOR

0.47
%

4.35
%

817.84
%

 MXN TIIE 28D

5.44
%

10.53
%

93.57
%

(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.

 2023

The main factors that contributed the most to the changes in the fair value of KEXIM’s trading derivatives in 2023 were
CCSs using floating rates in MXN (MXN TIIE 28D) or fixed rates in Euro on the buy side paired with fixed rates in USD on the sell side.

A numerical presentation of the changes in exchange rates and interest rates mentioned above from 2022 to 2023 are 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

16.78
%

 1 Euro (EUR)

W
1,351.20

W
1,426.59

5.58
%

 1 U.S. Dollar (USD)

W
1,267.30

W
1,289.40

1.74
%

 Interest Rates:

 MXN TIIE 28D

10.53
%

11.50
%

9.21
%

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

 Hedging Strategy

The Registrants also respectfully inform the Staff that it is KEXIM’s hedging strategy to try to manage and mitigate risks
related to foreign currency and interest rate exposures, such that all the gains and losses from derivative instruments and the related hedged items, together with the gains and losses on foreign exchange transactions and valuations (captured in the
“net gain (loss) on foreign exchange transaction” line item on KEXIM’s financial statements, which embodies the impact of foreign currency exposures in KEXIM’s hedged items), usually offset one another to a substantial extent.

 Mr. Thomas Kluck

August 26, 2024

  p.
 4

 Although the changes in KEXIM’s net gain (loss) on
hedging derivative assets and the gain (loss) on the trading derivative components included in net gain (loss) on financial assets at fair value through profit or loss appeared to be the largest drivers of the increase in KEXIM’s income between
2022 and 2023, these were largely offset by changes in the net gain (loss) on the fair value hedged items components included in net other operating income (expenses) and net gain (loss) on foreign exchange transactions, as shown below in the
excerpt from KEXIM’s separate statements of comprehensive income for the years ended December 31, 2023 and 2022 (left) and the relevant numbers extracted from the notes to KEXIM’s separate financial statements for the years ended
December 31, 2023 and 2022 that show the line items that largely offset one another (right):

 THE EXPORT-IMPORT BANK OF KOREA

SEPARATE STATEMENTS OF COMPREHENSIVE INCOME

FOR THE YEARS ENDED DECEMBER 31, 2023 AND 2022

2023

2022

(Korean won in millions)

 OPERATING INCOME:

 Net interest income (Notes 24 and 37):

 Interest income

W
5,856,490

W
3,070,500

 Interest expenses

(4,971,276
)

(2,118,108
)

885,214

952,392

 Net commission income (Notes 25 and 37):

 Commission income

464,744

362,932

 Commission expenses

(30,189
)

(26,194
)

434,555

336,738

 Dividend income (Note 26)

61,970

60,627

 Net gain (loss) on financial assets at FVTPL (Note
27)

209,808

(305,507
)

 Net gain (loss) on hedging derivative assets (Notes 20
and 28)

2,013,401

(3,223,739
)

 Net gain (loss) on financial investments (Note 29)

726

(47
)

 Net gain (loss) on foreign exchange
transaction

(1,062,884
)

514,938

 Net other operating income (expenses) (Note
30)

(931,214
)

3,173,480

 Additional impairment loss on credit (Note 31 and 37)

(279,070
)

(677,995
)

 General and administrative expenses (Note 32)

(271,357
)

(261,423
)

 Total operating income

1,061,149

569,464

 NON-OPERATING INCOME (Note 33):

 Net gain (loss) on investments in associates and subsidiaries

7,177

5,545

 Net other non-operating income (expenses)

(6,982
)

(4,143
)

195

1,402

 PROFIT BEFORE INCOME TAX

1,061,344

570,866

 INCOME TAX EXPENSES (Note 34)

(338,592
)

(183,955
)

 PROFIT FOR THE YEAR

722,752

386,911

2023

2022

(all in Korean won in millions)

 27. Gain (Loss) on Financial Assets at FVTPL

 Trading derivatives:

 Gain on valuation

618,916

1,567,207

 Loss on valuation

-563,390

-2,330,999

 Gain on transaction

1,646,358

1,617,433

 Loss on transaction

-1,600,700

-1,235,833

 Sub-total

101,184

-382,192

 28. Gain (Loss) on Hedging Derivatives

 Gain on hedging instruments

2,856,110

492,483

 Loss on hedging instruments

-842,709

-3,716,222

 Sub-total

2,013,401

-3,223,739

 Net Gain (Loss) on Foreign Exchange Transaction
(this item only shows up on the Income
Statement — no separate note)

-1,062,884

514,938

 30. Other Operating Income (Expenses)

 Other operating income:

 Gain on fair value hedged items

282,391

3,439,247

 Other operating expenses:

 Loss on fair value hedged items

-1,210,415

-273,771

 Sub-total

-928,024

3,165,476

 Total Net Amount Relating to All Derivatives
(sum of all
yellow-highlighted numbers above)

123,677

74,483

As shown above, the net amount relating to gains and losses on all of KEXIM’s derivatives and foreign
exchange transactions/valuations were W74.5 billion in 2022 and W123.7 billion in 2023, which KEXIM regards as the net impact on its profit (loss) for the year relating to derivatives and foreign exchange
and interest rate fluctuations, which falls under KEXIM’s target range that it strives to maintain under its risk management policy.

 Mr. Thomas Kluck

August 26, 2024

  p.
 5

 The Registrants respectfully acknowledge the Staff’s
comments and advise the Staff that they have revised the relevant paragraph on pages 8-9 and page 23 of the Registration Statement, through Amendment No. 1, as follows, and plan to provide a similar level of disclosure where relevant in
the Registrants’ future filings, to the extent relevant:

MD&A section (pages 8-9):

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 in
2023;(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 (see “—Financial Statements and the Auditors—Notes to Separate Financial Statements as of and for the years ended December 31, 2023 and
2022—Note 27”); and

•

 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; and, which in turn resulted mainly from changes in exchange rates (including MXN,
USD and EUR) and interest rates (including MXN TIIE 28D) between 2022 and 2023 that impacted the valuation of our various interest rate swap and cross-currency swap derivative products in 2023 (see “—Financial Statements and the
Auditors—Notes to Separate Financial Statements as of and for the years ended December 31, 2023 and 2022—Note 28”).

•

 a 58.8% decrease in additional impairment loss on credit to W279 billion in 2023
from W678 billion in 2022, mainly reflecting a general improvement in the overall asset quality of our loan portfolio in 2023, in particular with regard to our large refinery project in the Middle East.

These factors were in large part offset by:

•

 a change in net other operating income (expenses) to net expenses of W931 billion in 2023
from net income of W3,173 billion in 2022, primarily due to change in net gain (loss) on fair value hedged items to a net loss of W928 billion in 2023 from a net gain of
W3,165 billion in 2022 (see “—Financial Statements and the Auditors—Notes to Separate Financial Statements as of and for the years
ended December 31, 2023 and 2022—Note 30”); and

•

 a change in net gain (loss) on foreign exchange transactions to a net loss of
W1,063 billion in 2023 from a net gain of W515 billion in 2022, primarily due to increased volatility in exchange rates in 2023.

In
 addition, a 58.8% decrease in additional impairment loss on credit to W279 billion in
2023 from W678 billion in 2022, mainly reflecting a general improvement in the overall asset quality of our loan portfolio in 2023, in particular with regard to our large refinery project in the Middle East, contributed to the increase in net income.

For
 a description of our strategies and policies on derivative products, which we utilize primarily to hedge our risks relating to fluctuations in various foreign currencies and interest rates, see “—Description of Assets and
Liabilities—Derivatives.”

 Derivatives section (page 23):

 Derivatives

The objective in our strategy and policies on derivatives is to actively manage and minimize our foreign
exchange and interest rate risks. It is our policy to hedge all currency and interest rate risks wherever possible (taking into consideration the cost of hedging). We use various derivatives, including foreign exchange forwards and options, interest
rate swaps, and cross currency swaps. These derivatives are classified as hedging instruments if hedge accounting
method is applied, and if not, as trading derivatives for accounting purposes. See “—Financial Statements and the Auditors—Notes to Separate Financial Statements as of and for th