Russia Sanctions & Technology Controls

On February 24, 2022, the US and its allies, including NATO members and other independent nations
around the globe, imposed sweeping sanctions and technology controls against Russian parties
(government institutions, banks, public and private sector companies, and persons) operating inside and
outside of the Russian Federation. This is a very fluid situation and monitoring of US government
websites is essential in terms of export activities
. New US sanctions and controls are expected to be
added frequently. Recently, Belarus and occupied territories within Ukraine have also had sanctions
imposed. These actions by the US government mean that US businesses must be more vigilant in the
export of their goods, services and/or technology in terms of:

  • understanding export control classifications and associated restrictions (EAR99 products are now subject to Military End-Use (MEU) restrictions in Russia, for example);
  • obtaining certifications that collect key screening elements, including the end user, intended end use and ownership; (foreign resellers/distributors should not reexport merchandise to Russia or Ukraine)
  • conducting screening checks on all parties to the transaction (be mindful that buyers may be wholly or partially owned by sanctioned Russian entities, possibly making them blocked parties);
  • understanding new limitations on licensing policy and the use of license exceptions related to Russian transactions and requesting licenses where applicable, prior to export.
  • Any of your foreign customers that export to Russia must ensure that their product contains no more than 25% US-origin controlled content (de minimis rules).

Companies must possess a clear understanding of their responsibilities regarding end-use, end-user, and market where the good, service and/or technology is destined, as well as any and all license obligations for that export. Screening prior to shipment is key.

Ongoing information on sanctions and controls are found on the following websites and links:

Businesses of all sizes should use the tools the US Government has made available to stay up-to date as this is a fast moving and often changing environment. The US government provides readily accessible screening tools to help determine if organizations or individuals are on parties of concern/restricted parties or sanctioned entities lists. These tools, along with proper training on utilization, can support a robust screening effort as part of a company’s internal trade compliance program.

• Treasury Department – OFAC – Consolidated Sanctions List (Non-SDN Lists)

• Commerce Department – Bureau of Industry and Security (BIS) – Consolidated Screening List

These sanctions will have implications for your business operations in other ways. SMEs should be particularly mindful of vulnerabilities and exposures within their supply chain. Recommendations include:

Diversify Supply Chain Inputs: SMEs should review the lower layers of it supply chain. For example, even if a business has a sourcing arrangement with two different suppliers in two different locations, if both suppliers source raw materials from the same Ukrainian sub-supplier, then there could be threats to the continuity of operations as the situation worsens.

Warehousing, Inventory Banks & Safety Stock: The Just-In-Time (JIT) model is efficient but it’s also incredibly tenuous if there are any breaks in the supply chain. Identify key inputs that may be impacted and begin amassing safety stock and inventory where possible.

Lock in Transportation and Shipping Rates (to the Extent Possible): Given the volatile fluctuations in oil pricing, which will have impacts on all forms of transportation, lock in transportation and shipping rates as soon as possible. Companies are partnering with third-party logistics providers in order to defray some of the increasing volatility across labor, warehousing, transportation, and other logistics.

Contract Review: For customer and supplier relationships that could be impacted, it is once again time to get out those contracts to see: (a) whether the contracts contain a force majeure provision; (b) whether the force majeure provisions cover events such as war, embargoes, etc.; and (c) assess whether the force majeure clauses provide termination rights and what the associated notice requirements are. Finally, even if there is no force majeure provision in the applicable contract, the parties may have certain rights to suspend performance under the doctrine of commercial impracticability, depending upon the particular circumstances.

For questions, contact your local Small Business Development Center (SBDC), US Export Assistance Center (USEAC) across the US, or the BIS help desk. These entities can also help you identify a trusted trade advisor or legal counsel for further information.

Humanitarian relief: Donors should consider making their contribution through a reputable organization with a well-known performance record which will satisfy all compliance requirements directly related to the sanctions

Canadian Tariffs on Alabama Products: $49 Million

Canada is Alabama’s #1 export destination, with $4.19 Billion in goods sent north in 2017; Canada accounts for 19% of Alabama’s $21.7 billion in total exports.  Beginning on July 1, Alabama’s exporters will face stiff retaliatory tariffs on about 6% of those Canada-bound products; additional tariffs are estimated at $49 million.

  • Steel products: $38 million
  • Aluminum: $5.3 million
  • Pipe/Tubing: $2.2 million

Additional products impacted include plywood, prepared food products, paper products, and manufactured goods (washing machines, refrigerators).
For the complete list, download: Estimated Impact of Canadian Tariffs on Alabama Exports

EU Tariffs: Alabama businesses to pay $44 million

Based on Alabama’s exports to the European Union in 2017, the European Union’s retaliatory tariffs will cost Alabama businesses about $44 million.  The bulk of the tariffs (91%) are targeted at flat-rolled steel products; small businesses will likely be impacted by the tariffs levied on the remaining categories, including motorcycles, door & window frames, and fencing.

The EU will begin charging import duties of 25 percent on a range of U.S. products on Friday, June 22, 2018, in response to U.S tariffs imposed on EU steel and aluminum early this month.  The European Commission formally adopted a law allowing duties on 2.8 billion euros ($3.2 billion) worth of U.S. goods, including steel and aluminum products, farm products (including sweetcorn and peanuts), bourbon, jeans, and motorcycles.

The chart below shows Alabama’s exports to the EU in 2017, along with the retaliatory tariff rate and amount (had the tariff been applied to last year’s exports).

Download PDF: Impact of 20June EU Tariffs on AL

Brooks Named to AL District Export Council

Michael Brooks has been appointed by the U.S. Secretary of Commerce to the Alabama District Export Council (DEC), a private, non-profit organization of international business people who provide guidance and assistance on international markets to local businesses in conjunction with the U.S. Commercial Service office.  Brooks is the Associate Director of the William R. Bennett Alabama International Trade Center, an economic development and outreach unit of the University of Alabama’s Culverhouse College of Business.

The District Export Council is an honor granted by the U.S. Secretary of Commerce to an individual, based on energetic leadership, position in the local business community, knowledge of day-to-day international operations, interest in export developments, and willingness and ability to devote time to council activities.

Brooks is the third representative from UA’s Culverhouse College of Business to join the Alabama DEC.  Other members include Bill Cummins, Executive State Director of the Alabama Small Business Development Center Network, and Nisa Miranda, Director of the UA Center for Economic Development.

“The Alabama District Export Council’s members provide expertise on exporting to support and augment the efforts of the U.S. Commercial Service and Export Alabama Alliance to help more Alabama companies sell internationally,” according to the Commercial Service Director for Alabama, Robert Stackpole.

Brooks has 20 years of experience in international trade, and has worked with hundreds of companies in Alabama – and throughout the southeast- to help them enter new markets and increase export sales.  He teaches a senior-level course in Import-Export Management at UA, and has earned the Certified Global Business Professional (CGBP) credential from NASBITE International.

The AITC, established in 1979 by Dr. William R. Bennett, professor of international marketing in UA’s College of Business, delivers export research, training, and financing services to businesses in Alabama, and provides students with hands-on internship experience. It is a part of the Alabama SBDC Network, which is funded in part by the SBA to provide professional business advising services at no cost to Alabama’s small business community. Participating businesses are required to follow a well-defined scope of work and report their economic successes: job creation, increase in sales, capital investment, jobs retained and business started.

The councils’ mission, according to the national website, is to “encourage and support exports of goods and services that strengthen individual companies, stimulate U.S. economic growth and create jobs.”

EXIM Bank Joins Forces with AITC

Washington, D.C. – Today the Export-Import Bank of the U.S. (EXIM) announced the launch of its Regional Export Promotion Program (REPP), a joint effort between EXIM and regional organizations with a view to stimulating U.S. export sales abroad and bolstering job growth at home.

EXIM-Bank-AlabamaThe program, which already boasts 38 members across 26 states and two U.S. territories, is welcoming applications from potential members.

“Since 2009, EXIM has demonstrated a historic commitment to small business exports, and our local partners were key contributors to that success,” said Fred P. Hochberg, chairman and president of EXIM. “Through REPP, the Bank will continue to grow our network of regional, state, and local partnerships we need to ensure small businesses have additional tools and access to U.S. Government resources for exporters.”

Benefits of the program for companies, especially small businesses, include assistance with outreach and counseling; introduction to marketing and training materials; and access to qualified finance experts, lenders, insurance brokers, and U.S. Government export resources.

The Alabama International Trade Center, for example, assists small businesses in Alabama to enter foreign markets and expand their export sales and is part of The University of Alabama’s efforts to boost the state’s economic development.

“The Alabama International Trade Center at The University of Alabama has a thirty-five year history of working with EXIM Bank programs, and we look forward to growing that relationship with the new Regional Export Promotion Program,” said Bill Cummins, executive state director of the Alabama Small Business Development Center Network. “I’ve seen first-hand how EXIM programs really help small businesses grow their international sales, create jobs, and improve Alabama’s economy.”

Organizations eligible for membership include local, regional, or state economic development organizations or World Trade Centers that assist small businesses.

For more information on joining the program, please visit the REPP application page at

EXIM is an independent federal agency that supports and maintains U.S. jobs by filling gaps in private export financing at no cost to American taxpayers. The Bank provides a variety of financing mechanisms, including working capital guarantees and export credit insurance, to promote the sale of U.S. goods and services abroad. Almost ninety percent of its transactions directly serve American small businesses.

In fiscal year 2015, EXIM approved $12.4 billion in total authorizations. These authorizations supported an estimated $17 billion in U.S. export sales, as well as approximately 109,000 American jobs in communities across the country.

Small business exporters can learn about how EXIM products can empower them to increase foreign sales by clicking here. For more information about EXIM, visit