경제안보 시대의 아웃바운드 투자 규제 비교 연구: 미국, EU, 대만의 제도 분석과 한국에의 시사점

초록

Technology leakage through outbound investment has emerged as a security challenge that traditional export controls cannot adequately address. In response, the United States and other advanced economies have introduced outbound investment screening mechanisms. This study compares the United States, the European Union, and Taiwan to explain the divergence of their institutional models and to derive design principles and constraints relevant to Korea. Using weaponized interdependence as its analytical framework, it shows that three variables—position in global technology networks, economic dependence on China, and degree of alliance cohesion—help explain variation in regulatory types. The United States adopted a prohibition-type model through the OISP, Taiwan has long maintained a prior-approval system shaped by cross-strait relations, and the EU has pursued a monitoring-based approach coordinating divergent member-state interests. Korea is characterized as a “dilemma-type” country that cannot readily adopt any of these models. Its current framework lacks a legal basis for integrated screening of strategic investments combining capital and technology, while Korea also faces limited chokepoint capabilities, high economic dependence on China, and U.S.-led demands for regulatory alignment. Rather than proposing a full Korean model, this study derives design principles from comparative analysis: limiting technological linkage to core security technologies, adopting a risk-based and gradual approach, using nationally neutral legal language, differentiating screening by investment type, ensuring enforceability, and pursuing international cooperation alongside regulatory autonomy. It argues that such discussions must also consider external constraints, including the risk of Chinese economic retaliation and intensifying U.S.-led alignment pressures. The study thus offers a comparative benchmark and a starting point for future institutional design discussions in Korea.

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