Russia Sanctions and Export Controls
Since the February 24, 2022, Russian invasion of Ukraine, the scope and severity of U.S. sanctions and export controls imposed on Russia have expanded significantly. There were already sanctions in place on Russia since the country’s 2014 incursions into Ukraine, cyberattacks, malign influence, use of chemical weapons, and election meddling. Visit our Russia Country Commercial Guide for a comprehensive overview of these sanctions.
U.S. exporters should consider conducting due diligence for all transactions involving Russia and Russian entities or individuals and may wish to keep in mind the substantial sanctions that have been levied against the Russian banking and financial sector, which greatly complicate payments. Transportation and logistics in/out of Russia have also become more complicated, in part due to restrictions on air and maritime links. These actions have been coordinated extensively with European and Asian allies. U.S. exporters should be aware that the United Kingdom, European Union, Canada, Japan, Australia, and other allies and partners have also imposed sanctions against Russia in response to the invasion.
ITA does not offer legal advice to U.S. companies on sanctions or export controls, nor does it administer sanctions or export controls. However, there are many informational USG resources available to U.S. exporters that can help companies with their due diligence when considering opportunities in Russia. ITA also maintains the Consolidated Screening List, a list of parties for which the United States Government maintains restrictions on certain exports, reexports, or transfers of items. These tools are a consolidation of multiple export screening lists of the Departments of Commerce, State, and the Treasury and may be used as an aid to industry in conducting electronic screens of potential parties to regulated transactions.
Recent Executive Orders Related to Sanctions (Selected)
Selected recent executive orders related to current sanctions.
- EO 14024 (April 15, 2021 - Blocking Property with Respect to Harmful Foreign Activities of the Russian Government)
- EO 14039 (August 20, 2021 - Blocking Property with Respect to Russian Energy Export Pipelines)
- EO 14066 (March 8, 2022 - Prohibiting Certain Imports and New Investment)
- EO 14068 (March 11, 2022 - Prohibiting Certain Imports, Exports, and New Investment)
- EO 14071 (April 6, 2022 - Prohibiting New Investment in and Certain Services to the Russian Federation)
Information on Economic Sanctions
Administered by the Department of the Treasury’s Office of Foreign Assets Control (OFAC)
- Office of Foreign Assets Control (OFAC) - home page
- OFAC sanctions search tool
- Recent Actions (not limited to Russia)
- General License 6C of January 17, 2023 (exempting agricultural commodities and equipment/medicine/medical devices)
- General License 13D of February 24, 2023 (authorizing certain administrative transactions such as taxes, licenses, fees, etc.)
- July 2022 Fact Sheet, on Preserving Agricultural Trade and Communication
- Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin (November 22, 2022)
- Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin (February 3, 2023)
Information on Export Controls
Administered by the Bureau of Industry and Security (BIS), Department of Commerce
- BIS Russia & Belarus - home page
- Russian Industry Sector Sanction Lists - Part 746, supplement 2, 4, 5, “Luxury Goods” List
- Request a BIS Advisory Opinion
- Commerce – State – Treasury Joint Alert on Impact of Sanctions and Export Controls on Russia (October 14, 2022)
- BIS Lists of Parties of Concern - Denied Persons List, Entity List, Unverified List, Military End User List
State Department Resources on Russia Sanctions and U.S. Government Actions
U.S. Department of State resources on Russia sanctions and U.S. government actions.
- Foreign Policy-Related Sanctions Programs (not limited to Russia)
Other U.S. Government Actions Affecting U.S. Trade with Russia and Belarus (Selected)
- Federal Aviation Administration (FAA) Blocks Russian Aircraft from U.S. Airspace (March 2, 2022)
- Presidential Proclamation Regulating the Anchorage and Movement of Russian-Affiliated Vessels to United States Ports (April 21, 2022)
- Presidential Proclamation Raising Import Duties on Certain Articles from the Russian Federation (June 27, 2022)
- U.S. Department of Commerce Revokes Russia’s Market Economy Status in Antidumping Proceedings (November 10, 2022)
- White House Fact Sheet: On One Year Anniversary of Russia’s Invasion of Ukraine, Biden Administration Announces Actions to Support Ukraine and Hold Russia Accountable (February 24, 2023)