한국의 무기 수출 통제 체계 개선 방향 -독립적 규제위원회 도입의 필요성과 방향-

This study analyzes the limitations of South Korea's arms export control system and proposes improvements through the establishment of an Independent Arms Export Control Commission by comparing the cases of the United States and Germany. South Korea's current system, which is primarily managed by the Defense Acquisition Program Administration (DAPA), maintains a certain level of administrative efficiency. However, it faces significant challenges, including a lack of parliamentary oversight, insufficient transparency, limited inter-agency cooperation, and inadequate alignment with international norms. In the United States, Congress exercises strong oversight, ensuring democratic control and policy consistency through the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR). Meanwhile, Germany operates a multi-agency cooperation system centered on the Federal Security Council (Bundessicherheitsrat), but its non-transparent decision-making process is often criticized. This study argues that South Korea should adopt an independent regulatory body that integrates the transparent oversight mechanisms of the U.S.with Germany's inter-agency cooperation model. The proposed commission would involve multiple agencies—including DAPA, the Ministry of Foreign Affairs, the Ministry of National Defense, the Ministry of Trade, Industry and Energy, and the Ministry of Justice—to ensure fairness and objectivity in the arms export approval process. Additionally, it would be responsible for ensuring compliance with international norms, such as the Wassenaar Arrangement (WA), the Missile Technology Control Regime (MTCR), and the Arms Trade Treaty (ATT). To achieve these goals, the study suggests introducing a multi-stage review process and a parliamentary reporting systemto enhance transparency while balancing national security interests with international responsibilities. The establishment of an Independent Arms Export Control Commissionwould not only enhance South Korea's global credibility and defense industry competitiveness but also solidify its position as a responsible arms-exporting nationcommitted to international security and legal standards.