Jang Seok-kwang

 


The author is the general secretary of the Academy of National Intelligence.

 

 

 

On Feb. 12, the U.S. Central Intelligence Agency released a Chinese-language video on YouTube encouraging Chinese soldiers to secretly contact the CIA. Though only about 90 seconds long, one subtitle drew attention: “Choosing this path is my way of fighting for my family and my country.” The message appeared designed to ease the guilt or psychological conflict Chinese military personnel might feel about cooperating with a foreign intelligence service.

 

A similar scene unfolded in Korea during the Cold War. Richard Lawless, a former U.S. deputy undersecretary of defense, published a memoir in 2023 titled “Hunting Nukes.” The book recounts his time as a CIA officer stationed in Seoul in the mid-1970s and describes efforts to halt South Korea’s nuclear weapons development. Lawless portrays the South Koreans who leaked information about the program not as traitors but as patriots who helped prevent the threat posed by North Korea.

 

Iranian Kurdish fighters from the Kurdistan Freedom Party (PAK) take part in a training session at a base on the outskirts of Erbil, Iraq February 12, 2026. [REUTERS/YONHAP]

 

What may appear as betrayal to some can be recorded as patriotism from another perspective. That is the harsh reality of intelligence competition among states. Major powers such as the United States, China and Russia have long engaged in invisible struggles for information to advance their national interests. Countries may have allies, but there is no such thing as a friendly espionage law.

 

On March 5, South Korea’s Cabinet approved a revision to the Criminal Act expanding the definition of espionage. Previously limited largely to acts benefiting “enemy states” centered on North Korea, the law now applies to foreign countries in general. South Korea has begun confronting the reality of global intelligence competition through its legal system.

 

At the center of such activity lies HUMINT, or human intelligence. Those regarded as collaborators or agents on one side may be labeled spies on the other. The revised espionage law reflects the growing use of HUMINT by foreign governments. While operational methods differ by country, the contrast between the United States and China illustrates the modern landscape of intelligence competition.

 

The two powers differ first in their objectives. The United States focuses primarily on national security and military advantage. China places greater emphasis on economic gain and technology acquisition to strengthen national competitiveness and expand global influence. These differences shape their targets, recruitment methods, operational structures and time strategies.

 

The contrast appears clearly in target selection. The United States tends to concentrate on individuals at the core of national security, including senior government officials, military commanders, nuclear specialists and members of terrorist organizations. China’s targets span a much broader range. Researchers in advanced technology, corporate executives, universities and industrial supply chains all become potential sources. Academic exchanges, cultural networks and overseas Chinese communities can also become part of the information environment.

 

Recruitment methods also differ. U.S. intelligence agencies have traditionally relied on financial incentives and ideology. Political dissatisfaction or ideological motivations often serve as important entry points. During the wars in Iraq and Afghanistan, the United States worked closely with Kurdish armed groups to obtain operational intelligence. To protect sources facing retaliation, Washington has provided support such as Special Immigrant Visas and refugee status, reinforcing trust within its networks.

 


 

China, by contrast, often emphasizes long-term relationship building. Economic cooperation, business opportunities, research partnerships, investment and professional networking can gradually create channels through which information flows over time.

 

Operational structures further highlight the difference. In the United States, intelligence activity is led by professional agencies such as the CIA. In China, the Ministry of State Security plays the central role, but the network is much broader. State-owned enterprises, private companies, scholars, students and overseas Chinese communities can all become part of intelligence activities.

 

Time horizons also differ. American HUMINT often focuses on short-term intelligence that supports policy decisions or military operations. China frequently pursues long-term strategies aimed at technological accumulation, industrial competitiveness and expanding influence.

 

These differences are connected to broader political and strategic cultures. The United States operates under oversight from Congress and the judicial system, emphasizing legal legitimacy and procedures. China tends to prioritize efficiency. Under the concept of “unrestricted warfare,” boundaries between war and peace blur and a wide range of social resources, from corporations to diaspora networks, may be mobilized for intelligence purposes.

 

Such structural differences also intersect with Korea’s own circumstances. China’s National Intelligence Law requires individuals, companies and organizations to cooperate with national intelligence work. In effect, the entire society can become a potential HUMINT network. The challenge is that such risks may extend beyond China’s borders.

 

Korea’s openness and active exchanges create an environment in which Chinese intelligence activities could potentially take root. As of June last year, about 970,000 of the 2.73 million foreign residents in Korea held Chinese nationality, the largest group. Confucius Institutes, which have drawn suspicion as platforms for influence operations in some countries, were first established globally in Korea and the country hosts the largest number in Asia. The more open and interconnected a society becomes, the wider the space in which foreign intelligence activities may operate.

 

A revision to the Criminal Act is passed during the eighth plenary session of the 432nd National Assembly (extraordinary session) at the National Assembly in Yeouido, Seoul, on Feb. 26. The amendment was approved with 163 votes in favor, three against and four abstentions out of 170 lawmakers present among 296 members. The revised bill includes provisions expanding the scope of espionage crimes. [NEWS1]

 

The United States, meanwhile, enforces strict rules on information security and law enforcement. Cases such as Robert Kim, Col. Baek Dong-il and Sue Mi Terry show that even actions undertaken with allies in mind can lead to prosecution if classified information is transferred. In intelligence work the principle is simple: countries may have allies, but espionage laws recognize no friendship.

 

Years ago during a business trip to Southeast Asia, a junior colleague working as a consul joked that he had been a nobody in Korea but was “somebody” in his host country. He meant that his official status gave him access to influential figures he could not have approached at home.

 

Another colleague who worked in Korea’s counterintelligence field once made a similar observation. He said he had never seen a Korean official refuse a meeting when contacted by U.S. or Chinese intelligence services. Many even spoke proudly about such approaches, pleased to have been recognized by major powers.

 

Even in the world of HUMINT, differences in national power remain clear. That gap becomes particularly visible in the enforcement of espionage laws. Legal provisions may appear similar, but how firmly they are applied ultimately depends on a country’s will and capability. Korea’s revised espionage law will soon face its first real test. How it is enforced in reality remains to be seen.

This article was originally written in Korean and translated by a bilingual reporter with the help of generative AI tools. It was then edited by a native English-speaking editor. All AI-assisted translations are reviewed and refined by our newsroom.