Editor’s Note (November 2026): This article has been updated to reflect recent developments in Russia and current trade policy considerations for U.S. exporters.
If you’re thinking about exporting to Russia, well… you probably shouldn’t.
While once a significant market for certain U.S. exporters, Russia today is one of the most restricted and high-risk destinations for U.S. goods. Since Russia’s invasion of Ukraine in 2022, the United States has imposed sweeping sanctions and export controls that severely limit what U.S. companies can sell to Russia.
As a result, exporting to Russia now requires far more than standard export documentation. Companies must carefully evaluate whether the product, buyer, end user, end use, financial institution, and shipping route are allowed under U.S. law.
While some limited trade continues, U.S. exports to Russia have dropped dramatically, and many transactions require a license or are prohibited altogether. Exporters should not ship to Russia without first conducting thorough sanctions screening, export classification, and legal review. In this article, we’ll explore those reasons as well as take a brief look at the history of U.S. trade with Russia.
U.S. goods exports to Russia fell sharply after Russia launched its full-scale invasion of Ukraine in February 2022. Before the invasion, U.S. companies sold about $6.4 billion in goods to Russia in 2021, according to the U.S. Census Bureau.
The Office of the U.S. Trade Representative reports that U.S. goods exports to Russia totaled $582.7 million in 2025. That was up 10.3% from 2024 and still about 91% below 2021 levels. U.S. goods imports from Russia totaled about $3.8 billion in 2025, bringing two-way goods trade to about $4.4 billion.
The United States expanded export controls and sanctions in response to the invasion, building on restrictions already in place following Russia’s occupation of Crimea. Those measures now shape what U.S. companies can sell to Russia, whom they can do business with and how they can get paid.
Even when a shipment is legally permitted, arranging transportation and payment can be difficult. Before committing to a delivery date, confirm that your carrier and freight forwarder will handle the shipment and that your bank can process the payment. Review the proposed route and the parties involved, including any intermediaries in third countries.
In April 2026, the United States extended for another year the emergency authority governing the movement of Russian-affiliated vessels at U.S. ports. The Federal Register notice explains the extension.
The U.S. Commercial Service suspended its operations in Russia in July 2021. The International Trade Administration’s Russia Market Overview says the agency continues to cover the Russian market from Washington, D.C., and Eurasia.
Russia should no longer be treated as a normal export market.
The U.S. Bureau of Industry and Security (BIS) administers export controls under the Export Administration Regulations (EAR). Its Russia and Belarus controls cover exports, reexports and certain transfers within either country. They can also reach some foreign-produced items under the EAR’s foreign direct product rules. See BIS guidance on Russia and Belarus for current requirements.
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) administers separate sanctions. Those sanctions can restrict transactions involving certain individuals, companies, banks, vessels or activities. A shipment can require a review under both sets of rules. Start with OFAC’s Russia-related sanctions guidance for applicable restrictions and authorizations.
It’s critical to understand the regulations covering exports to Russia. You must be concerned with complying with export regulations no matter where you ship, exporting to Russia—even when it’s allowed—is extremely different from shipping to Canada. It’s a part of the world where more items are controlled, so you need to understand what is required of you and what you risk if you don’t do your job in complying with those regulations.
The first step in ensuring export compliance is determining who has jurisdiction over your goods: the U.S. Department of Commerce under the Export Administration Regulations (EAR) or the State Department's Directorate of Defense Trade Controls (DDTC).
If your goods fall under the jurisdiction of the Commerce Department, which most products do, you must determine if your export requires authorization from the Bureau of Industry and Security (BIS, part of the Commerce Department). To do so you need to answer the following questions:
There are three ways to classify your products for export controls: You can self-classify your products, submit a SNAP-R request for a ruling, or rely on the product vendor to provide the information. If you’re self-classifying, Shipping Solutions Product Classification Software makes the process easier than manually searching through codes and regulations. You can give it a try for free here.
By classifying your product correctly, you’ll be protecting yourself from potential fines, penalties and even jail time.
Next, companies must use the ECCN codes and reasons for control described above to determine whether or not there are any restrictions for exporting their products to specific countries. Once they know why their products are controlled, exporters should refer to the Commerce Country Chart in the EAR to determine if a license is required.
Before exporting anything to Russia, companies should determine the product’s Export Control Classification Number (ECCN), confirm whether the item is subject to Russia-specific license requirements, and review whether a license exception is available. In many cases, license applications involving Russia are reviewed under restrictive policies or may be denied.
Although a relatively small percentage of all U.S. exports and reexports require a BIS license, exporting to Russia does require a license in most cases, and BIS has tightened the availability of license exceptions. Additionally, virtually all exports and many reexports to embargoed destinations and countries designated as supporting terrorist activities require a license. Countries fitting that bill are Cuba, Iran and North Korea.
Part 746 of the EAR describes embargoed destinations and refers to certain additional controls imposed by the Office of Foreign Assets Control (OFAC) of the Treasury Department.
The Shipping Solutions Professional export documentation and compliance software includes an Export Compliance Module that uses the ECCN code for your product(s) and the destination country to tell you if an export license is required. If indicated, you must apply to BIS for an export license through the online Simplified Network Application Process Redesign (SNAP-R) before you can export your products.
BIS also controls a range of products identified in Part 746 of the EAR. For Russia and Belarus, Supplement No. 4 lists industrial goods, Supplement No. 5 lists luxury goods and Supplement No. 6 lists other covered items.
When reviewing a listed product, check the applicable tariff code and product description, then follow the order of review in § 746.8. These controls can trigger a license requirement for some items designated EAR99. For more detail, see how Schedule B and HTS codes factor into Russia-related export controls.
Deemed Exports
Surprise! You may be an exporter without even knowing it! Deemed exports, or the disclosure of information or services rather than an actual product, is an important issue to pay attention to when exporting. A deemed export occurs when technology or source code (except encryption and object source code, which is separately addressed in the EAR under 734.2(b)(9)), is released to a foreign national within the United States.
Sharing technology, reviewing blueprints, conducting tours of facilities, and other information disclosures are considered potential exports under the deemed export rule and should be handled accordingly. You can learn how to apply this principle here.
Restricted party lists (also called denied party lists) are lists of organizations, companies or individuals that various U.S. agencies—and other foreign governments—have identified as parties that one can’t do business with.
There are several reasons why a person or company may be added to a restricted party list. For example, they may be a terrorist organization or affiliated with such an organization, they may have a history of corrupt business practices, or they may otherwise pose a threat to national security.
Restricted party screening (or denied party screening) refers to the process in which a company checks a potential customer or business partner against one or more of the restricted party lists to ensure they are not doing business with a restricted party.
The primary restricted party lists in the United States are published by the Department of Commerce, Department of State, and Department of Treasury. However, several other agencies produce lists as well. These agencies recommend that companies perform restricted party screening periodically and repeatedly throughout the movement of goods in the supply chain.
Exporters should screen every Russia-related transaction against the following:
This should include indirect shipments through third countries because sanctions evasion and diversion are major enforcement concerns.
Shipping Solutions Restricted Party Screening Software makes it fast and easy to check hundreds of lists at once, and it provides detailed information about potential matches, so you can make an informed decision about what to do next. Give it a try for free.
Should you choose to export to Russia, it’s imperative you check every single restricted party list every time you export because:
In addition to restricting exports to entities on one of the government’s bad-guy lists, it is illegal to export to entities that don’t appear on any of OFAC’s Specially Designated Nationals (SDN) lists but that have at least 50% ownership by one or more entities that do appear on one of the SDN lists. This is referred to as the 50 Percent Rule.
This means your customer as an entity may not be blocked, but you could be in violation if your customer is owned, in aggregate, directly or indirectly by a blocked party or parties with a 50% or more ownership stake.
The 50 Percent Rule means that OFAC compliance screening requires more than simply looking up names of people or companies on a list—it requires making determinations about ownership. This can be a difficult and time-consuming process, but one that can be helped by utilizing software that includes ownership information. Check out the blog post, OFAC Compliance Best Practices, for more details.
BIS has a separate rule that expands certain export controls to affiliates of listed entities. In November 2026, BIS extended the suspension of its Affiliates Rule until January 10, 2027. OFAC’s ownership rule continues to apply.
A major Russia compliance risk is diversion through third countries. Goods may be routed through intermediaries in nearby or neutral markets before ultimately reaching Russia.
Exporters should be especially cautious when orders involve:
Tariffs are no longer the primary trade concern for U.S. companies considering exports to Russia. Since 2022, sanctions, export controls, financial restrictions, and licensing requirements have become the dominant barriers.
Exporters should still classify products using HS and Schedule B codes, but the more important question is whether the transaction is legally permitted at all.
In limited cases, yes—but many exports to Russia are prohibited, restricted, or require a license. Before shipping to Russia, U.S. companies must review sanctions, export controls, restricted-party lists, end-use restrictions, and licensing requirements. Russia is no longer a routine export market, and exporters should not proceed without a careful compliance review.
This is one in a series of articles exploring exporting to specific countries across the globe—we previously featured China, the United Kingdom, Japan, Mexico, Canada, India, Brazil, Germany, France, the Netherlands, the EU, South Korea, Singapore, Belgium, and Taiwan.
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