Vet the specific supplier, product, and transaction—not the supplier’s country alone. Review who controls the company, where its technology and subcontractors come from, how it protects and recovers services, where data goes, whether U.S. export controls apply, and whether the contract makes these commitments enforceable. Scale the evidence you require to the supplier’s access and importance to your business.
Start by defining what the supplier will do
Before sending a questionnaire, describe the relationship and its consequences. A company supplying a component has a different risk profile from one hosting customer records, administering production systems, or maintaining software with privileged access.
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- Identify the service or product: software, hardware, cloud hosting, managed services, engineering, support, or components.
- List the systems and business processes that would depend on it, the supplier’s access privileges, and the data it could see or handle.
- Set the outage the business can tolerate and identify what happens if the supplier—or a critical provider it relies on—becomes unavailable.
- Decide what evidence is proportionate to that access and business impact. A generic corporate overview is not enough when the purchase is for a particular product or service.
NIST Special Publication 1326, published July 8, 2026, frames ICT due diligence as investigating pertinent information about a supplier or product to inform acquisition decisions. Its assessment dimensions are Foreign Ownership, Control, or Influence (FOCI), Provenance, Resilience, Foundational Cyber Practices, and Supply Chain Tiers. Those categories offer a useful structure for a U.S. buyer’s review.
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Confirm the legal entity that will sign the agreement and perform the work. Trace parent entities, beneficial ownership where available, governance, material affiliates, operating locations, and any relevant jurisdictions. Ask who develops, hosts, maintains, updates, and supports the product; request a current list of critical subcontractors and hosting regions; and establish how the supplier will notify you when those arrangements change.
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For a product or service that depends on other providers, ask where the important components and software originate, how dependencies are tracked, and whether any critical source is single-provider or difficult to replace. Request enough detail to identify which functions are performed by the supplier and which are delegated. NIST SP 1326 specifically identifies FOCI, provenance, and supply-chain tiers as due-diligence topics.
A Korean headquarters or place of incorporation does not, by itself, answer who controls a supplier or whether a particular product is suitable. Assess the named company, offering, ownership and control, operating footprint, and transaction together; the NIST framework does not determine whether an unnamed supplier is acceptable.
Validate the product and software provenance
Ask for evidence tied to the product and version you intend to buy, rather than relying on broad company-wide statements. For software and connected products, review the architecture and dependency information, secure development and release practices, how updates are signed and delivered, the vulnerability intake and remediation process, and end-of-support dates.
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- How are releases authorized, integrity-checked, and distributed?
- How does the supplier receive vulnerability reports, assess severity, notify customers, and deliver fixes?
- Which functions are handled by subcontractors, and what visibility does the supplier have into their work?
- Does the evidence identify the applicable product or service version and the period it covers?
These questions help test the provenance and tier visibility called for in NIST SP 1326 without treating a product inventory or questionnaire as proof that every dependency is safe.
Assess cybersecurity and recovery evidence
Request written policies and operational evidence that match the supplier’s actual access and the service being purchased. CISA’s supplier-assessment materials identify areas such as supplier contract obligations, asset integrity, administrative-access training, incident detection, and recovery. For a consequential service, review evidence in these areas:
- Identity controls, privileged access, and workforce training.
- Asset management, secure configuration, and software integrity.
- Vulnerability handling, logging, monitoring, and incident escalation.
- Backup integrity, recovery arrangements, and recovery testing.
- Incident history relevant to the service, including how the supplier communicates and cooperates with customers.
If the supplier offers an independent assurance report or certification, examine its scope, exclusions, assessment period, and covered service. Confirm that the product or environment being evaluated is the one your company will use. A certificate or completed questionnaire is not a substitute for checking whether controls fit your deployment.
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Record any material gaps with an owner, due date, and any compensating control or approval condition. The depth of that evidence review should reflect the supplier’s access and the impact of failure, consistent with NIST SP 1326’s risk-oriented due-diligence dimensions.
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Map data flows before sharing information
Build a data-flow record that follows information through collection, processing, storage, support, and deletion. Ask the supplier to identify its role, the purpose for handling each data category, the locations where data is stored and processed, the locations from which staff can access it, and every subprocessor or onward recipient that may receive it.
- Classify the information: personal, sensitive personal, financial, regulated-sector, or other restricted business data.
- Document storage and processing locations, remote support access, subprocessors, and onward transfers.
- Set retention periods, deletion requirements, and how the supplier will confirm deletion at the end of service.
- Establish the applicable transfer mechanism, security controls, incident notification, and evidence or audit rights.
Can a U.S. company transfer data to a Korean service provider? The answer depends on the data, parties, service, and applicable rules; the supplier’s location alone does not settle it. The U.S. Trade Representative’s 2026 National Trade Estimate describes limits under Korea’s Personal Information Protection Act (PIPA) on some transfers of personal data outside Korea. It also reports localization requirements for personal credit and unique identification information processed by financial institutions, and restrictions on foreign cloud providers for national core technology workloads. These are not a blanket rule that all data must remain in Korea. Confirm current Korean requirements for the actual data and service with privacy counsel or the responsible compliance team.
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Screen the actual technology transfer for U.S. export controls
Identify any U.S.-origin or U.S.-controlled commodity, software, technology, technical data, or service that may be supplied to, accessed by, or transferred to the Korean supplier or its downstream users. Include remote access, reexports, and transfers within another country in the analysis. Determine the item’s classification and consider the destination, end user, and end use.
The U.S. Department of Commerce’s South Korea export-control guide explains that the Export Administration Regulations (EAR) cover dual-use commodities, software, and technology, as well as certain U.S.-person activities. It identifies the Consolidated Screening List as an aid for screening parties to regulated transactions. Screen the supplier and relevant owners, intermediaries, and named end users, and repeat screening when relevant parties or destinations change. Defense articles and services may instead be under State Department International Traffic in Arms Regulations (ITAR) jurisdiction.
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Ask how the supplier would sustain or restore the service through a disruption, and how exposed your company is to a failure elsewhere in its supply chain. Review geographic and provider concentration, critical subcontractor dependencies, capacity, support coverage, incident communications, backup arrangements, and recovery plans. Consider operational and financial stability as part of the supplier’s ability to keep supporting the product.
Plan for the possibility that the supplier fails, changes a critical provider, or ends product support. Establish what data and configuration you can export, how quickly a replacement could be deployed, whether another provider can use the exported materials, and what transition assistance is required. NIST SP 1326 includes resilience and supply-chain tiers among its due-diligence dimensions.
Make the comparison consistent across candidates
Use the same evidence-based rubric for each candidate. A side-by-side assessment makes differences visible without assuming that a supplier’s nationality predicts its risk. Record the evidence and its scope, not just a yes-or-no questionnaire response.
| Review area | What to compare | Useful evidence or record |
|---|---|---|
| Ownership and control | Ownership, governance, material jurisdictions, and transparency | Entity and ownership information; identified operating locations and relevant affiliates |
| Provenance and dependencies | Product, software, component, and service origins; subcontractor depth and concentration | Product- and version-specific dependency information; critical subcontractor and hosting-region list |
| Security | Controls relevant to the purchased service, supplier access, and data | Scoped policies, operational evidence, and assurance reports with scope and period checked |
| Resilience and exit | Incident response, recovery capability, continuity, and replacement feasibility | Recovery arrangements, dependency information, data-export details, and transition commitments |
| Data and legal fit | Data location, access, transfer mechanism, and sector-specific implications | Documented data flows, subprocessor access, retention, deletion, and applicable transfer analysis |
| Export controls and parties | Item classification, parties, end users, end uses, and ability to support compliance | Classification and screening records for the actual transaction, maintained by the responsible compliance function |
| Contract accountability | Audit access, change notices, incident duties, and transition obligations | Executed agreement and service schedules with measurable commitments |
| Operational fit | Service levels, support coverage, integration effort, and continuity needs | Documented service commitments and an assessment against the buyer’s business requirements |
Put the decision into the contract and operating record
Translate accepted requirements into the agreement and service schedules. CISA’s supplier-assessment materials include contractual security obligations as an assessment area. Terms should reflect the risks identified in the review and specify who must do what, by when, and what evidence the buyer can obtain.
- Limit permitted data use and access, and set location commitments where applicable.
- Require approval or notice for material subcontractor changes, with relevant obligations flowing down to subcontractors.
- Set minimum security controls, vulnerability-handling expectations, and incident notification and cooperation duties.
- Provide appropriate audit or evidence rights and define continuity and recovery commitments.
- Specify retention, return or deletion, deletion confirmation, and transition assistance at termination or service end.
Keep a decision record listing the risks identified, evidence reviewed, unresolved gaps, owners, approval conditions, and review cadence. Route transaction-specific Korean and U.S. obligations to the relevant security, privacy, export-control, procurement, and legal owners before approval. This is a procurement framework, not a legal determination or security audit: suitability depends on the named supplier, product and version, ownership and control, data flows, industry, contract, U.S.-origin technology, end users and end uses, and current applicable rules.
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