What Do You Need to Export to Russia from the Czech Republic?

Are you a foreign company operating in the EU and unsure how to navigate the current sanctions against Russia? This guide provides a clear roadmap for identifying prohibited goods, avoiding the risks of illegal re-export, and protecting your business from severe penalties. As a leading Czech law firm in Prague, EU, we will show you the essential steps for compliant trade.

• This article was revised and updated with the latest legal information in 2025. We first published it in 2019.

Do you need advice on this topic? Contact the ARROWS law firm by email office@arws.cz or phone +420 245 007 740. Your question will be answered by "Mgr. Vojtěch Sucharda", an expert on the subject.

The New Reality for EU Exporters: Why Trading with Russia is a Legal Minefield

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."

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 office@arws.cz.

FAQ – Legal tips about sanctioned goods

• What exactly are "dual-use goods"?
  These are products that can be used for both civilian and military purposes, such as powerful computers or navigation systems. Their export is strictly controlled under EU regulations. Need to verify your product? Email us at office@arws.cz.
• My product isn't on any list. Am I safe?
  Not necessarily. EU law includes "catch-all" clauses that can prohibit the export of unlisted goods if there is a suspicion of military end-use.11 For legal certainty, an expert consultation is vital. Get tailored legal solutions by writing to office@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 office@arws.cz.

Risks and penalties	How ARROWS helps
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 office@arws.cz.
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 office@arws.cz.
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 office@arws.cz.
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 office@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 office@arws.cz.

Our experts on the topic:

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 – office@arws.cz.

Risks and penalties	How ARROWS helps
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 office@arws.cz.
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 office@arws.cz.
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 office@arws.cz.
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 office@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 office@arws.cz.

FAQ – Most common legal questions about exporting to Russia

1. Can I still export goods to Russia if they are not on any sanctions list?
In theory, yes, but it is extremely high-risk. You must conduct thorough due diligence on the end-user and contractually secure yourself against re-export. Even with non-sanctioned goods, issues can arise if they could support Russian industry. For an assessment of your specific case, contact us at office@arws.cz.

2.Our company has a long-term business partner in Kazakhstan. What should we do?
Even with existing partners, you must conduct a new, in-depth due diligence review and revise all contracts to include the mandatory "no re-export to Russia" clause. The legal landscape has changed, and old agreements no longer offer sufficient protection. We can help you review your contractual relationships; write to office@arws.cz.

3. What should I do if I suspect our customer has breached the contract and re-exported our goods?
Act immediately. Under EU regulations, you have a duty to report such suspicions to the competent authorities. Following the correct procedure can significantly mitigate your potential liability. For crisis consulting and representation in this matter, we are available at office@arws.cz.

4. What are the first steps to assessing my company's export risks?
The first step is an audit of your existing contracts and business partners. The second is creating an internal compliance program that sets clear rules for all future transactions. We can prepare a complete risk audit for you. Start with a consultation by emailing office@arws.cz.

5. What about payments? Can we accept payments from Russian entities for permitted goods?
The payment system is heavily restricted. Many Russian banks are disconnected from international systems, and deposits from Russian entities in the EU are subject to a €100,000 limit. Every transaction must be carefully assessed to avoid having funds frozen. If you are facing a payment issue, please contact us at office@arws.cz.

6. Does ARROWS provide services outside the Czech Republic, for example in Turkey or the UAE?
Yes. Through our ARROWS International network, we can provide legal services and due diligence directly in these jurisdictions. This is crucial for effectively managing the risks associated with re-export. For international legal support, contact us at office@arws.cz.

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