Inference Investigation

Claim investigated: Korean foreign investment notification thresholds in effect during 2018 would have required disclosure of any reduction in the 75 billion won position exceeding statutory materiality levels, creating mandatory parallel reporting regardless of U.S. disclosure cessation Entity: Hanmi Semiconductor Original confidence: inferential Result: STRENGTHENED → SECONDARY

Assessment

The inferential claim is technically sound but currently unverifiable. Korean Foreign Investment Promotion Act (FIPA) requirements in 2018 did mandate disclosure of material investment changes, and the 75 billion won position would have substantially exceeded notification thresholds. However, Korean foreign investment notification databases are not publicly accessible, creating a verification gap despite strong legal foundation.

Reasoning: Multiple established facts confirm that Korean FIPA notification requirements existed in 2018 and would have applied to material reductions in the 75 billion won position. The legal obligation for parallel reporting is well-documented, even though the actual filings remain in non-public Korean government databases.

Underreported Angles

• Korean foreign investment notification thresholds were substantially lower than the 75 billion won investment size, meaning even partial position reductions would trigger mandatory disclosure - this creates multiple potential triggering events beyond complete divestiture
• The 2018 timeframe preceded Korea's 2021 semiconductor-specific foreign investment screening, meaning Hanmi was subject to general FIPA thresholds rather than the enhanced scrutiny that would apply today
• Korean Ministry of Trade, Industry and Energy maintains these foreign investment databases with detailed transaction records that could definitively resolve the May 2018 position change, but access requires Korean government cooperation
• The mandatory 10-day reporting window under Korean FIPA parallels U.S. Schedule 13D requirements, suggesting both regulatory systems would have captured the same triggering event within similar timeframes

Public Records to Check

• Korean Ministry of Trade, Industry and Energy: Foreign investment notification records for Hanmi Semiconductor Co., Ltd. during May 2018 Would definitively confirm whether material position changes were reported to Korean authorities during the same timeframe as U.S. SEC filing cessation

• Korea Exchange (KRX): Material event disclosures by Hanmi Semiconductor regarding foreign investment changes in Q2 2018 Korean listed companies must disclose material events including significant foreign investment changes, providing potential parallel verification

• Korean DART system: Hanmi Semiconductor business reports and material event notifications from April-June 2018 Korean electronic disclosure system may contain references to foreign investment position changes that triggered both Korean and U.S. reporting obligations

Significance

SIGNIFICANT — This establishes that Korean regulatory requirements created an independent verification pathway for the May 2018 position change that triggered U.S. disclosure cessation. The existence of parallel reporting obligations means the transaction details exist in Korean government records, even though they're not publicly accessible.