The Fair Trade Commission (FTC) will launch a 'Key Investigation Planning Team' on October 1, comprising about 40 members. This team, made up of Investigation Divisions 1, 2, and 3, marks the revival of the investigation bureau, often referred to as the 'business undertaker,' after 21 years. The FTC has also expanded significantly, increasing its staff from 474 at the end of 2024 to 768 currently, a rise of approximately 62%.
However, as the agency's authority and expertise grow, so does the market value of its former officials. The market is already responding.
From January 2021 to July 10 of this year, there have been 263 lawsuits related to collusion filed with the FTC. Among these, the top 10 law firms in South Korea have taken on 191 cases (excluding duplicates), accounting for 72.6% of the total. Kim & Chang led with 32 cases, followed by Hwawoo with 30, Taepyeongyang with 29, Sejong with 25, and both Gwangjang and Barun with 18 cases each, while Yulchon handled 16.
Coincidentally, many former FTC officials have moved to large law firms. From January 2016 to the end of August this year, 86 individuals transitioned from the FTC to the top law firms. Kim & Chang had the highest number with 21, followed by Taepyeongyang with 13, Yulchon with 11, Hwawoo with 10, and both Gwangjang and Sejong with 8 each. Notably, 44 of these former officials moved to the top three law firms handling collusion cases: Kim & Chang, Hwawoo, and Taepyeongyang, representing more than half of the total.
The market value of these former officials is also reflected in their salaries. The average monthly salary of the 21 FTC retirees who moved to Kim & Chang increased from approximately 8.25 million won to 30.59 million won, nearly 3.7 times. For Hwawoo, the average rose from 6.73 million won to 21.54 million won, about 3.2 times, and for Taepyeongyang, from 6.21 million won to 18.23 million won, approximately 2.9 times.
This raises a fundamental question: what are law firms paying such high prices for in former FTC officials? Is it their expertise in fair trade law, or their 'network' with current officials?
It is not uncommon for a former FTC official who was investigating a company to later represent that same company at a law firm, advising on cases being investigated by former colleagues and juniors. This concern is not merely hypothetical. Evidence has shown that the FTC's existing external contact reporting system is not functioning effectively. According to data submitted by Park Seong-hoon, a member of the National Assembly's Political Affairs Committee, 50 FTC employees have been caught failing to report contacts with external parties from 2021 to 2025. The number of detected cases decreased from 18 in 2021 to 5 in both 2022 and 2023, but then rose again to 9 in 2024 and 13 last year. The number of detected cases has increased by 2.6 times in the past two years. Among these, only one employee received formal disciplinary action under the National Public Service Act, which was a pay reduction last year.
With the establishment of the Serious Crimes Investigation Agency (SCIA) and the Prosecution Service on October 2, the demand for former officials is expected to rise further. From a corporate perspective, there is likely to be a market where companies seek former FTC officials during the investigation phase, SCIA veterans during the investigation phase, and former prosecution officials during the indictment phase. This is what is referred to as the 'relay of former officials.' As authority previously concentrated in the prosecution is distributed, a paradox arises where the market for former officials becomes segmented across the FTC, police, SCIA, and the Prosecution Service. This will likely lead to more cases being funneled to large law firms that can recruit former officials, driving legal costs to unprecedented levels. The burden of these costs will ultimately fall on ordinary citizens. In this significant transformation of the criminal justice system, 'controlling former officials' has emerged as a major challenge.
* This article has been translated by AI.
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