The Korea Foundation (KF) said on Monday that its U.S. office registered under the U.S. Foreign Agents Registration Act (FARA) on the Department of Justice’s (DOJ) recommendation, disclosing four years of activities it said ended in 2024.

The Oct. 8 filing covered activities from Jan. 1, 2021, through Dec. 31, 2024, and notably also served as a termination notice. The DOJ’s public registry records both registration and termination on Oct. 8, 2026.

“In accordance with the U.S. Department of Justice’s recommendation for FARA registration of the Korea Foundation USA (KFUSA), KF reviewed all relevant matters, including the legal aspects and activities subject to registration, and decided to proceed with the registration,” KF headquarters said in a statement to Korea Pro.

South Korea’s foreign ministry did not provide a comment in response to questions emailed the same day.

A separate foreign-principal entry identifies KF in South Korea as the organization on whose behalf KFUSA, the registrant named in the DOJ filing, acted.

The filing followed a July 2025 Korea Pro investigation into the foundation’s multimillion-dollar funding of U.S. think tanks. Multiple experts interviewed for that report said its U.S. activities should have required FARA registration.

FARA, enacted in 1938 to combat Nazi propaganda, requires individuals or entities acting “at the order, request or under the direction or control” of a foreign principal to register with the Justice Department if they engage in political activities within the U.S.

In its registration statement and foreign-principal and activity disclosure, KFUSA described operating a public study space in Washington, providing limited assistance for KF’s Next Generation Leaders Program and participating in discussions about Korean affairs.

The activities included making “Korea-related books, reports and multimedia” materials available to the public. The documents also identify KFUSA Director Sung Won Bae and Deputy Director Jaeseung Moon as participants in Korea-related “roundtables.”

“As noted above, all of these activities ceased operation as of Dec. 31, 2024. This registration thus also serves as a termination notice, effective Dec. 31, 2024,” KFUSA stated, explaining that it understood this to be the “proper” way to file retrospective registration and termination notices.

KFUSA registered more than 21 months after the stated cessation date. However, its statement did not explain why the filing covered that four-year period or what changed in the office’s operations to support its position that registration was no longer required after 2024.

“The simultaneous registration and termination was likely part of an agreement between the Korea Foundation and the DOJ, as a vehicle for the Korea Foundation to admit to certain past activities in exchange for a release from liability,” Jumin Lee, a partner at Los Angeles law firm Bird Marella, suggested to Korea Pro.

The DOJ did not respond to a request for comment as of Monday.

See more: How South Korea gave $9.4M to US think tanks while evading foreign agent laws

KF’s activities had reportedly caught the attention of U.S. authorities before the filing.

The July 2024 indictment of Korea expert Sue Mi Terry, a former Central Intelligence Agency analyst accused of failing to register as a foreign agent for Seoul, had exacerbated concerns within KF about being viewed as a foreign agent itself, according to Korea Pro’s 2025 investigation.

KFUSA’s Oct. 8 filing came five days before U.S. prosecutors filed a deferred prosecution agreement in the separate case against Terry.

The agreement deferred her prosecution for 12 months, subject to conditions, and does not mention KF.

“I don’t think the two are directly related,” said a former senior U.S. official. Terry’s legal representative was not immediately available to comment.

Questions also remain about the implications for grants negotiated or paid directly by KF’s South Korean headquarters, rather than its U.S. office, and for the 15 think tanks, universities, nonprofit organizations and other groups listed as recipients of $171,181 in disbursements retrospectively disclosed in the filing’s appendix.

“FARA is a broad, nebulous law that, not while without important utility, can also be unique in its impacts. It’s hard to tell what the outcomes will be at this point,” the former U.S. official said.

Any registration obligation for organizations receiving KF grants would depend on their own activities and relationship with the foundation.

But several past U.S. recipients of KF support also have internal restrictions on foreign government funding or activities requiring FARA registration.

The Atlantic Council says “a government cannot fund a report on itself or bilateral relations.” The Center for American Progress says foreign government donors cannot fund specific research or objectives.

The Council on Foreign Relations (CFR) says it does not accept foreign government funding, or grants or memberships from entities majority owned or controlled by foreign governments. Brookings prohibits activities that would require its employees or the institution to register under FARA.

The retrospective filing doesn’t mean any of these institutions violated their funding policies or incurred FARA registration obligations.

The Atlantic Council, Brookings and CFR did not respond to questions about the filing and their funding policies.

Before the October filing, KF had advertised another round of U.S. research funding.

A call for 2027 U.S. policy research proposals, published June 29, invited applications from American think tanks and university-affiliated research institutions for projects analyzing Korea-related issues and developing policy recommendations.

The program guidelines also offer support for emerging policy specialists and Korea-focused chairs or fellowships. Eligible expenses include researchers’ salaries, travel, honoraria and publication costs.

The October registration does not establish whether subsequent grants administered by KF headquarters are subject to separate FARA disclosure requirements.

Edited by John Lee 

Additional reporting by Jeongmin Kim and Joon Ha Park