USA to Russia shipping is a lane where the legal position comes before the logistics. Before anyone asks about a Vladivostok routing, a transit time or a rate, the exporter has to establish whether United States law allows the sale at all. This guide is a compliance-first explainer built on official US pages and regulation text (the CFR as shown on Cornell LII) read in October 2026, plus one carrier FAQ and one port-operator page for context. It sets out what the Bureau of Industry and Security (BIS) and the Treasury's Office of Foreign Assets Control (OFAC) say, which documents the rules describe, and what a shipper should confirm with sanctions counsel before any booking. It does not describe a way around any control, and nothing here is an offer to carry restricted goods.
Where the Lane Stands in Plain Terms
BIS's Russia and Belarus country guidance says BIS "has taken swift and severe action to impose stringent export controls on Russia", that these restrictions "have also been applied to Belarus", and that both countries are "subject to broad in-country transfer controls". The page says it is not a substitute for the Export Administration Regulations (EAR).
The trade statistics give context, although the page does not say what caused the changes. The US Census Bureau's trade in goods with Russia page reports US goods exports in millions of US dollars, nominal and not seasonally adjusted.
| Period | US goods exports to Russia (USD million) |
|---|---|
| 2021 | 6,388.2 |
| 2022 | 1,655.4 |
| 2023 | 606.1 |
| 2024 | 528.3 |
| 2025 | 582.7 |
| 2026, January to August | 393.5 |
Exports in 2025 were about 9% of the 2021 level (582.7 divided by 6,388.2 is 0.091). Trade has not stopped, but the page gives totals only and does not say which goods make up the flow. Nothing here says that any particular product is allowed.
Two Separate US Regimes
An exporter faces two different sets of rules, administered by different agencies, and clearing one does not clear the other.
BIS: the licence requirements in section 746.8
Section 746.8 of the EAR, as shown on the Cornell LII text of 15 CFR 746.8, says its licence requirements apply in addition to those on the Commerce Control List (CCL) and elsewhere in the EAR, including the end-use and end-user controls in part 744. The core rule is paragraph (a)(1): "A license is required to export, reexport, or transfer (in-country) to or within Russia or Belarus any item subject to the EAR and specified in any Export Control Classification Number (ECCN) on the CCL."
The other paragraphs add further triggers:
- A foreign direct product rule (paragraph (a)(2)) and a military end user and procurement rule (paragraph (a)(3)).
- Items used in certain oil and gas exploration or production (paragraph (a)(4)).
- Items listed in supplements 4, 5 and 6 to part 746 (paragraphs (a)(5) to (a)(7)).
- Certain EAR99 software (paragraph (a)(8)).
The word "reexport" matters for a lane that mentions a third-country port: the text covers reexports and transfers as well as exports from the United States, so a routing through another country is not a separate answer, subject to the exclusions in paragraph (a)(12).
The licensing policy in paragraph (b) is strict. Applications under paragraph (a)(3) are reviewed under "a policy of denial in all cases", and those under paragraphs (a)(1), (2) and (5) to (8) are also reviewed under a policy of denial. The text then lists types reviewed case by case, including items needed for health and safety, wind-downs, and "items that meet humanitarian needs, including applications for items that are predominantly agricultural or medical in nature". Case-by-case review is not approval.
Licence exceptions are narrow. Paragraph (c)(2) says none may overcome the requirements in paragraphs (a)(1), (2) and (4) to (8) except a short list, such as news-media items.
OFAC: sanctions on transactions and parties
OFAC's Russian Harmful Foreign Activities Sanctions page lists Executive Order 14024 of 15 April 2021 and the regulations at 31 CFR Part 587 among the program's authorities. It says certain activities "may be allowed if they are licensed by OFAC", and distinguishes general licences, which let US persons act without applying, from specific licences, which are an "Authorization from OFAC to engage in a transaction that otherwise would be prohibited". The page lists General License 13S dated 8 October 2026, a sign of how recently this area has changed.
One general licence is relevant to the goods question. General License 6D, dated 12 June 2024, authorises transactions under the Part 587 regulations related to the production, manufacture, sale, transport or provision of agricultural commodities, agricultural equipment, medicine, medical devices and certain related items, subject to its exclusions. The exclusions include account-related transactions involving certain financial institutions and the Russian central bank, and transactions prohibited by three other executive orders, with two carve-outs for named determinations under one of them. The licence also states in Note 2: "Nothing in this general license relieves any person from compliance with any other Federal laws or requirements of other Federal agencies." In other words, an OFAC authorisation does not replace a BIS licence where the EAR requires one.
On who the counterparty is, OFAC's FAQ 398 explains that its 50 Percent Rule "speaks only to ownership and not to control", and urges caution with non-blocked entities in which blocked persons hold a significant interest below 50 percent or may control by other means.
What About the Vladivostok Routing?
This article does not describe a USA to Vladivostok service, because no official source we read describes one. The FESCO page on cargo via the Commercial Port of Vladivostok says FESCO delivers containerised cargo "from China, Vietnam, Japan, Korea and countries of Southeast Asia" through the port. The United States is not named. If a counterparty proposes a routing for US-origin goods, treat it as "routing to be confirmed with the carrier", and treat the legal question above as unchanged by the route. For what the port itself offers, see why Vladivostok is a strategic gateway for cargo.
Carriers decide for themselves. Maersk's FAQ on shipping to and from Russia answers "No" and says Maersk "has now stopped all vessel operations in Russia". The page is undated and mentions office closures planned for summer 2022, so read it as an older carrier position. Legal permission and carrier acceptance are separate tests.
Documents the Sources Describe
The regulations describe several documents and records that attach to an export from the United States. Whether each applies depends on the goods and the licence position.
| Item | What the source says |
|---|---|
| Electronic Export Information (EEI) | A statement to the US Government "that the transaction occurred as described". Required for items on the CCL going to Russia "regardless of value" unless an exemption applies, and for exports needing a licence application |
| Destination control statement | Exporters must put a statement on the commercial invoice when CCL items are shipped, with listed exceptions |
| Licence application | The applicant may cite 746.8 and the relevant paragraph (a), with a description in Block 9 (Special Purpose) |
| Records | Kept for five years from the latest of export, a known reexport, transshipment or diversion, or termination of the transaction |
The detail behind the table comes from 15 CFR 758.1, which says in paragraph (b)(10) that EEI is required "For all exports of items on the Commerce Control List to the People's Republic of China, Russia, or Venezuela, regardless of value". Under 15 CFR 30.37, exports valued at USD 2,500 or less per Schedule B number are exempt, number by number, and 758.1(b)(5) applies the filing requirement above that value. For CCL items going to Russia, paragraph (b)(10) applies "regardless of value" and names only the paragraph (c)(4) exemption (License Exception GOV), so ask counsel or a licensed customs professional whether the USD 2,500 exemption can be used at all. 15 CFR 758.6 requires the destination control statement, which begins "These items are controlled by the U.S. Government and authorized for export only to the country of ultimate destination", unless the shipment is made under a baggage or gift exception or the item is EAR99. 15 CFR 762.6 sets the five-year retention period, counted from the latest of the listed events.
The US export classification (ECCN or EAR99) is a separate question from the HS code used for customs; see what an HS code is.
Screening and Red Flags
The International Trade Administration's Consolidated Screening List describes itself as a list of parties for which the US Government maintains restrictions on certain exports, reexports or transfers of items, and tells users to screen potential buyers and end-users. BIS's red flags page links to a joint compliance note saying third-party intermediaries and transshipment points can be used to disguise sanctioned or listed parties and to obscure the true identity of Russian end users. The page does not mention freight forwarders.
What to Confirm Before Any Booking
- Classify the item: its ECCN, or EAR99, and whether it appears in supplements 4, 5 or 6 to part 746.
- Ask sanctions counsel whether a BIS licence is required, which licence exceptions (if any) apply, and what the review policy says for your type of item.
- Screen the buyer, consignee, end user and any intermediary against the Consolidated Screening List and OFAC's lists, including ownership and control questions.
- Check OFAC rules for the transaction and payment path, including whether a general licence such as 6D applies and whether its exclusions are triggered.
- Prepare the EEI, destination control statement and licence references, and set up the five-year record file.
- Ask each carrier in writing whether it accepts the booking, and do not assume that legal permission means carrier acceptance.
- Get written sign-off from counsel or a licensed customs professional before committing cargo.
For the wider picture, see Russia sanctions and compliance in logistics, how geopolitical changes can affect shipping routes, and our guide to the difference between a freight forwarder and a customs broker. For the Russian side of the paperwork, see common customs clearance challenges in Russia.
Work With RR Brothers and Logistics
RR Brothers and Logistics arranges sea freight and handles customs clearance from our Guangzhou headquarters and our offices in Coimbatore and Mumbai. We do not publish a USA to Russia or Vladivostok service, and we are not a substitute for your own sanctions counsel. If you have a lawful shipment in mind, tell us the cargo and the lane and we will advise whether and how we can handle it, without any promise in advance. You can also contact our team with questions.
Frequently Asked Questions
It depends on the goods, the parties and the licence position. BIS paragraph 746.8(a)(1) requires a licence for any item on the Commerce Control List, other paragraphs add further triggers, and OFAC sanctions apply separately. Confirm with sanctions counsel before any booking.
Under 15 CFR 758.1(b)(10), EEI is required for all exports of items on the Commerce Control List to Russia regardless of value, unless an exemption applies.
No. General License 6D Note 2 says nothing in the licence relieves any person from compliance with other Federal laws or the requirements of other Federal agencies. A BIS licence may still be required where the EAR says so.
Each carrier decides for itself. Maersk's FAQ answers "No" to shipping to or from Russia and says its wind-down allows no new business there. The page is undated, so ask each carrier in writing about the booking.
No such service is published on this site. Tell us your cargo and we will advise whether and how we can handle it, subject to compliance sign-off from your own counsel.
Sources
- BIS: Russia and Belarus country guidance
- 15 CFR 746.8: Sanctions against Russia and Belarus (Cornell LII)
- 15 CFR 758.1: Electronic Export Information filing (Cornell LII)
- 15 CFR 30.37: Exemptions from EEI filing (Cornell LII)
- 15 CFR 758.6: Destination control statement (Cornell LII)
- 15 CFR 762.6: Period of retention (Cornell LII)
- OFAC: Russian Harmful Foreign Activities Sanctions
- OFAC: Russia-related General License 6D (12 June 2024)
- OFAC: FAQ 398, entities owned by blocked persons (50% rule)
- International Trade Administration: Consolidated Screening List
- BIS: Identify red flags
- US Census Bureau: Trade in goods with Russia
- Maersk: Can I ship cargo to/from Russia at the moment?
- FESCO: Delivery of cargo via Commercial Port of Vladivostok
This article is general information, not legal, tax or customs advice. Rules, rates and procedures change; confirm current requirements with the relevant authority or a licensed customs professional before you ship. Regulatory references were checked against the official sources listed above on 31 October 2026.
Image credits: header photo by Sven Piper on Unsplash; photo by Steve Saunders on Unsplash; photo from zzkonst on Pixabay; photo by Camilo Rueda López on Unsplash. Used under the Unsplash License and the Pixabay Content License.
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