What Do You Need to Export to Russia from the Czech Republic?
A Legal Guide for Foreign Companies.
The days when exporting to Russia was primarily a matter of logistics and contracts are over. Today's reality is defined by a complex web of international sanctions that are constantly evolving. For any company operating from within the European Union, the key question is no longer "how to export," but "how to export legally and safely."

The New Reality for EU Exporters: Why Trading with Russia is a Legal Minefield
Since 2022, the EU has implemented over a dozen sanctions packages, creating a multi-layered legal environment. These restrictions go far beyond military hardware, affecting key sectors of the Russian economy, including finance, energy, transport, advanced technology, and industrial machinery.
The scope of these measures is vast. Sanctions now apply to over half of the EU's original export volume to Russia, representing a value of more than €48 billion. Navigating this requires not just caution, but deep legal expertise.
At ARROWS, a law firm based in Prague, European Union, we handle cross-border commercial cases daily. Leveraging our ARROWS International network, built over ten years across 90 countries, we help foreign clients understand the current rules and structure their trade relationships to comply with all applicable regulations.
What Is Prohibited? Key Categories of Restricted Goods
The foundation of safe exporting is correctly identifying whether your goods are subject to a ban. The lists are long and technical, but certain key categories demand maximum attention.
How do I know if my products are banned?
The highest-risk category is dual-use goods—products with a primary civilian function that could be repurposed for military use. This extends beyond high-end technology.
Sanctions lists include items like semiconductors, advanced electronics, drones, specialized software, and even seemingly ordinary products like high-performance laptops, cameras, lenses, and radio navigation devices. Other banned categories include luxury goods, aerospace products, and oil refining technology.
These lists are often defined by technical parameters and Harmonized System (HS) codes. ARROWS lawyers can provide a crucial legal analysis to determine if your product falls into a restricted category, protecting you from unintentional violations. For an immediate assessment of your goods, write to us at consultation@arws.cz.
The Biggest Trap for Exporters: Re-export Through Third Countries
The greatest risk for EU-based exporters today is not direct trade with Russia, but unknowing participation in sanctions evasion. The scheme is simple but legally fatal for an unprepared company.
Why is avoiding direct shipments to Russia not enough?
Sanctions circumvention works by formally exporting goods to a third country that has not joined the sanctions—typically Turkey, Kazakhstan, Kyrgyzstan, Armenia, or the UAE. From there, the goods are re-exported to Russia.
Authorities are actively monitoring these flows. While direct EU exports to Russia have plummeted, exports of sensitive goods to these transit countries have skyrocketed—in Kyrgyzstan's case, by over 1600%. EU and national authorities, including the Czech Financial Analytical Unit (FAÚ), are aware of these schemes and maintain lists of suspicious entities.
A key defense mechanism is the contractual inclusion of a "no re-export to Russia" clause. Under Article 12g of EU Council Regulation No. 833/2014, this clause is mandatory for all contracts involving the export of sensitive goods (e.g., in aviation, firearms, high-priority items) to third countries.
ARROWS has extensive experience drafting and reviewing international contracts, including implementing robust "no re-export" clauses that provide legal protection. Need a contract prepared? Contact us at consultation@arws.cz.
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Risks and penalties |
How ARROWS helps |
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Criminal prosecution of company directors for indirect export of sanctioned goods to Russia. |
Drafting ironclad contracts: We ensure your contracts include a legally effective "no re-export" clause. Need a contract review? Write to consultation@arws.cz. |
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Financial penalties and asset freezes due to business with a re-exporting partner. |
In-depth partner due diligence: We vet your entire supply chain to uncover hidden links to Russia. Want to screen a business partner? Contact us at consultation@arws.cz. |
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Reputational damage and blacklisting of your company for suspected sanctions evasion. |
Legal opinions and compliance programs: We draft internal policies to demonstrate your due diligence and protect you during an inspection. Get tailored legal solutions by writing to consultation@arws.cz. |
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Seizure of goods by customs authorities on suspicion of Russia being the final destination. |
Representation before public authorities: We assist in negotiations with customs and other agencies to ensure the smooth processing of legal exports. Our lawyers are ready to assist you – email us at consultation@arws.cz. |
Vet Your Partners: Essential Due Diligence in the Supply Chain
In the current climate, the principle is simple: trust but verify. The legal responsibility for ensuring you are not dealing with a sanctioned person or entity rests with you, and this extends to indirect links.
How can you be sure who your end-user really is?
The basic tools are the official sanctions lists of the EU, USA, and other jurisdictions. In the Czech Republic, the Financial Analytical Unit (FAÚ) oversees sanctions compliance.
However, a simple name check is often insufficient. Complications like different transliterations from Cyrillic, hidden ownership structures via offshore companies, and incomplete public registers make this process highly unreliable. Even EU-based companies can be secretly owned or controlled by Russian entities.
This is where professional legal assistance is irreplaceable. As an international law firm operating from Prague, European Union, ARROWS utilizes specialized databases and our ARROWS International network to conduct thorough legal due diligence that uncovers even hidden risks. For immediate assistance, write to us at consultation@arws.cz.
The Practical Side: Documentation and Certification
Even if your goods are not sanctioned and your partners are vetted, you must pay maximum attention to the formal aspects of exporting. Customs authorities are on high alert, and any discrepancy can trigger suspicion.
What documents are needed for permitted exports?
Standard customs documents like the Single Administrative Document (SAD), invoice, and packing list remain essential. For market access to the Eurasian Economic Union (which includes Russia), many products require EAC (Eurasian Conformity) certification, the equivalent of the European CE mark.
Obtaining EAC certification requires submitting detailed technical documentation, user manuals, and the correct customs classification for your product. Even for permitted goods, all documentation must be flawless, as any ambiguity can give customs officials a reason to launch an investigation.
ARROWS provides comprehensive legal advice on obtaining necessary permits and certifications and will prepare all documentation to protect you from issues during customs clearance. Do not hesitate to contact our firm – consultation@arws.cz.
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Risks and penalties |
How ARROWS helps |
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Imprisonment of up to 8 years for directors under the Czech Criminal Code for violating international sanctions. |
Legal consultations and prevention: We provide legal advice that protects you from actions that could be classified as a criminal offense. Want to understand your legal options? Email us at consultation@arws.cz. |
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Corporate fines in the millions of euros and forfeiture of assets. |
Preparation of compliance documentation: We draft internal policies and other documents to prove your company acted with due diligence and in accordance with the law. Do you need documentation prepared? Contact us at consultation@arws.cz. |
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Dissolution of the legal entity as the ultimate penalty for a company under Czech law. |
Representation in court and before public authorities: In the event of an inspection or dispute, we will effectively represent you and defend your rights. Need legal representation? Write to consultation@arws.cz. |
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Ban on business activities and exclusion from public tenders, which can be fatal for a company. |
Professional training for employees and management: We train your team on sanctions policy and compliance, minimizing the risk of human error. Get certified training for your company at consultation@arws.cz. |
ARROWS: Your Partner for Secure International Trade
Exporting to Russia or neighboring countries today is about precise legal risk management. Every step, from partner selection and contract negotiation to final customs clearance, must be carefully considered and legally secured.
At ARROWS, we provide comprehensive support: we review and draft contracts, ensure the implementation of the "no re-export clause," conduct in-depth due diligence on your business partners, represent you before authorities, and prepare internal compliance programs to protect your company.
Our experience is backed by long-term service to over 150 joint-stock companies and 250 limited liability companies. We understand business needs and pride ourselves on speed and precision. Thanks to our ARROWS International network, we handle cases with cross-border elements daily.
We also connect our clients with valuable business and investment opportunities. We are always open to hearing about your innovative business ideas.
Let us handle the complex legal agenda so you can focus on your business. For a no-obligation consultation and a solution tailored to your situation, contact us at consultation@arws.cz.
Don't want to deal with this problem yourself? More than 2,000 clients trust us, and we have been named Law Firm of the Year 2024. Take a look HERE at our references.
About the author
Disclaimer:
The information contained in this article is for general informational purposes only and serves as a basic guide to the issue as of 2019. Although we strive for maximum accuracy, laws and their interpretation evolve over time. We are ARROWS Law Firm, a member of the Czech Bar Association (our supervisory authority), and for the maximum security of our clients, we are insured for professional liability with a limit of CZK 400,000,000. To verify the current wording of the regulations and their application to your specific situation, it is necessary to contact ARROWS Law Firm directly (consultation@arws.cz). We are not liable for any damages arising from the independent use of the information in this article without prior individual legal consultation.

