The U.S. House of Representatives passed H.R. 2913, the Ukraine Support Act, on June 4, 2025. If the Senate follows and the president signs it, your compliance framework will need to adapt to new sanctions, a foreign-direct product rule, and duties that alter Russian trade economics. The bill creates a trigger mechanism: every 90 days, the president must determine whether Russia is waging aggression against Ukraine, refusing good-faith negotiations, or violating a peace agreement. An affirmative determination sets a 15-day deadline for implementing specified sanctions, export controls, and a minimum 500% duty on Russian imports.
This isn't incremental policy. It's a structural shift in how sanctions and trade controls interact.
What Changed
The Act bundles three enforcement regimes into a single legislative package:
Sanctions expansion. The president must impose property blocking and visa restrictions on at least three of thirteen named Russian financial institutions, entities involved in Russian oil, gas, coal, and mineral extraction, and 22 identified senior government and military officials. Additional targets include anyone constructing or maintaining the Kerch Strait Bridge, foreign vessels transporting Russian oil in violation of the price cap, and global financial messaging providers servicing sanctioned Russian banks.
Export control codification. The Act introduces a Russia-specific foreign-direct product rule under the Export Administration Regulations. Foreign-produced items become subject to the EAR if they're the direct product of certain U.S.-origin technology or software and are destined for Russia or incorporated into items produced in or destined to Russia. The rule exempts items necessarily incident to communications and certain EAR99 or 5A992.c/5D992.c classifications covered by a Commerce or Treasury general license.
Trade duties. Upon an affirmative presidential determination, the Act mandates ad valorem duties of at least 500% on all goods and services imported from Russia, plus a 100% tax on interest or dividends earned by Russian or Belarusian governments from blocked sovereign assets.
Key Findings
The 90-day determination cycle creates compliance volatility. Your team can't treat this as a one-time implementation. Every quarter, the president must reassess the triggering conditions. If the determination flips from affirmative to negative (or vice versa), sanctions and duties shift within 15 days. You'll need monitoring protocols that track the determination status and alert stakeholders immediately when it changes.
The SWIFT provision is a direct operational threat. Section 317 requires sanctions on any global financial messaging or communications service provider that continues to service sanctioned Russian financial institutions. If SWIFT remains connected to any of the designated institutions under the Act, it faces blocking sanctions. That forces a binary choice for financial infrastructure providers and affects correspondent banking relationships with institutions relying on those providers.
The foreign-direct product rule expands your export control perimeter. If you've been treating foreign-manufactured goods as outside your EAR compliance scope, that changes. The new Russia FDPR captures foreign-produced items that are the direct product of U.S. technology or software, if they're Russia-bound or incorporated into Russia-destined items subject to the EAR. You'll need to map your supply chain for indirect U.S.-origin dependencies and assess whether your foreign manufacturing partners understand their new obligations.
The 500% duty threshold eliminates commercial viability. This isn't a tariff designed to raise revenue or protect domestic industry. It's a prohibition disguised as a duty. At 500%, no legitimate commercial import from Russia is viable. Your import compliance function should treat this as a de facto embargo for planning purposes, even though the legal mechanism is a tariff.
Sanctions on oil shipping create vessel-level risk. The Act targets any foreign vessel knowingly transporting Russian oil in violation of the price cap policy. This shifts compliance scrutiny from the cargo owner to the vessel operator. If you're financing, insuring, or chartering vessels, you need vessel-level screening protocols that confirm compliance with the price cap before any Russia-origin crude or refined products are loaded.
What This Means for Your Team
Your name screening system needs vessel identifiers. Sanctions on foreign vessels require you to screen IMO numbers, not just beneficial owners or operators. If your current screening workflow only checks entity names, you're missing the target. Add vessel registries to your data sources and build alerts for any vessel that appears on OFAC's Non-SDN list or that your intelligence feed flags for price cap violations.
Your export compliance function must audit foreign manufacturers. The new FDPR doesn't just affect your direct shipments. If you're selling U.S.-origin software or technology to a foreign manufacturer who incorporates it into products, and those products could end up in Russia, you're responsible for ensuring your customer understands and complies with the FDPR. That means contractual provisions, end-use certifications, and periodic audits of your downstream supply chain.
Your import team should prepare for a hard stop. Even if the 500% duty isn't implemented immediately, you can't rely on Russian imports as part of your supply chain. Start identifying alternative sources now. If you're currently importing raw materials, components, or finished goods from Russia, the economics will collapse the moment the president makes an affirmative determination.
Your transaction monitoring rules need a Russia-specific layer. The Act's sanctions reach beyond traditional SDN blocking. You'll need rules that flag transactions involving the thirteen named financial institutions (even before designation), payments related to Russian oil and gas extraction, and any wire transfers that route through or benefit sanctioned messaging providers. Update your Transaction Monitoring Rules to catch these patterns before they become violations.
Action Items by Priority
Immediate (within 30 days):
- Map your current exposure to Russian financial institutions, focusing on the thirteen named in the Act
- Audit your vessel screening capabilities; add IMO number checks if absent
- Review import manifests for Russian-origin goods; quantify financial exposure to the 500% duty scenario
- Brief senior management on the 90-day determination cycle and the 15-day implementation window
Short-term (60-90 days):
- Update your sanctions policy to address the new categories: oil shipping, SWIFT providers, Rosatom transactions, and Kerch Strait Bridge construction
- Build transaction monitoring rules for Russia oil/gas extraction entities and the named government officials
- Conduct a supply chain audit for foreign-manufactured goods with U.S.-origin technology content destined for or transiting Russia
- Draft contractual language for foreign manufacturing partners acknowledging the new FDPR obligations
Ongoing:
- Monitor presidential determinations every 90 days; set calendar alerts 10 days before each deadline
- Track Senate action on H.R. 2913 and coordinate with legal counsel on implementation timelines if enacted
- Review OFAC guidance on the new authorities as it's published; expect FAQs on the SWIFT provision and the vessel sanctions
