When exporters think about sanctions on Russia, the names that come up first are predictable: the European Union, the United States, the United Kingdom. Canada and Australia have been covered in a previous post in this series. But South Korea and Japan? For many exporters, the idea that these two Asian manufacturing powerhouses have imposed meaningful export restrictions on Russia comes as a genuine surprise.
It should not. Both countries moved quickly after February 2022, both operate export control frameworks that are deeply integrated with the international regimes coordinated by the G7 and the like-minded group, and both have expanded their restrictions steadily in the years since. More importantly for this post, both countries have specific relevance for exporters who are not Korean or Japanese: if your supply chain includes components, technology or intermediaries with Korean or Japanese connections, their controls may apply to you.
This post explains why South Korea and Japan belong in the same discussion, what their export restrictions on Russia actually cover, and what any exporter — regardless of where they are based — needs to know to understand the full picture.
If you are working through this series in order, the previous posts cover EU sanctions on Russia and Belarus and US and UK export sanctions. This post follows the same structure and the same scope.
Before going further, a consistent clarification about what this post does not cover. The following are deliberately excluded:
- Sanctions against specific individuals, oligarchs or Russian entities
- Banking and financial sanctions
- Import restrictions on Russian-origin goods
- Port access restrictions for Russian-flagged vessels
- Travel bans
What remains — and what this post focuses on exclusively — is the prohibition on exporting certain goods from South Korea and Japan to Russia.
Why South Korea and Japan in the Same Post?
The pairing makes more sense than it might initially appear.
Both countries are advanced economies whose industrial and technology sectors are among the most sophisticated in the world. Both are major exporters of semiconductors, precision components, industrial machinery and electronics — precisely the product categories that sit at the heart of the international effort to restrict Russia’s military and industrial capabilities. Both are members of all four major multilateral export control regimes: the Wassenaar Arrangement, the Australia Group, the Missile Technology Control Regime (MTCR) and the Nuclear Suppliers Group (NSG). This means their lists of controlled strategic goods were already substantially aligned with those of the United States and the European Union before the Ukraine-related restrictions were introduced.
Politically, both countries joined the coalition of “like-minded” states that coordinated their response to the February 2022 invasion — a coalition that includes the US, UK, EU, Canada and Australia, among others. Japan is a G7 member and participated directly in the G7-led coordination of sanctions packages. South Korea aligned closely with the G7 position, implementing restrictions that mirror the Common High Priority Items List (CHPL) identified in the US, UK and EU frameworks.
Both countries have also experienced the same enforcement challenge: goods being exported to Russia through third countries in Asia and Central Asia, and the challenge of tracing and prosecuting those routes. This shared problem has driven a parallel tightening of enforcement in both countries during 2024 and 2025, including the first criminal convictions for violations of Russia-related export restrictions in both jurisdictions.
For any exporter operating across multiple jurisdictions — or whose supply chain touches components, technology or intermediaries with Korean or Japanese origins — understanding these two frameworks is not optional.
The South Korean Framework: Foreign Trade Act and MOTIE
South Korea does not have a standalone sanctions law. Instead, its export restrictions on Russia operate through the existing export control framework established by the Foreign Trade Act, administered by the Ministry of Trade, Industry and Energy (MOTIE).
The key mechanism is the situational licence — a tool provided by Article 19.3 of the Foreign Trade Act, which allows the Minister of MOTIE to designate items that are not ordinarily classified as strategic goods but which, in light of changes in the international situation, require an export licence. For Russia and Belarus, MOTIE applies a policy of systematic licence denial for designated items, which in practice makes the situational licence requirement equivalent to a de facto export ban.
This creates two distinct layers of control that exporters need to understand:
The first layer is the strategic items list — the standard controlled goods list aligned with the Wassenaar Arrangement, MTCR, NSG and Australia Group. These items require a licence for export to any destination, and approvals for Russia are not granted.
The second layer is the catch-all list for Russia and Belarus — a list of non-strategic items that MOTIE has designated as requiring a situational licence specifically for exports to Russia and Belarus, on the grounds of their risk of military diversion. This list is where the most significant expansion has taken place since 2022.
When South Korea first imposed export restrictions on Russia in February 2022, the catch-all list was limited. By April 2023, through successive amendments to the relevant Public Notice, it had grown to 798 items — covering semiconductors, industrial machinery, petroleum gas refining equipment, steel industry components, chemical products, vehicles above certain value thresholds, and quantum computing components. MOTIE’s approach to this list is explicit: licences will not be granted for listed items, except in narrowly defined cases such as honouring pre-existing contracts or supplying wholly owned subsidiaries of Korean companies in Russia.
The expansion continued into 2024, when the list was extended to approximately 1,159 items, adding rechargeable batteries, heavy construction equipment and vehicles with engines larger than 2.0 litres. This last category was particularly significant: restrictions on Korean car exports to Russia through third countries had been systematically circumvented in the preceding years, and the vehicle-specific controls were a direct response to documented evasion patterns.
A separate notable development arrived in July 2024, when South Korea amended the Enforcement Decree of the Foreign Trade Act to establish an explicit legal basis for implementing unilateral export control measures independently of multilateral regimes. Before this amendment, South Korea’s autonomous action was constrained by its need to work within established international frameworks. The 2024 change allows MOTIE to act more quickly and independently when new security concerns emerge — a significant shift in the architecture of the Korean export control system.
In February 2025, a further round of amendments added 21 advanced-industry items and technologies as strategic goods. The same amendment introduced a narrow exception allowing certain humanitarian medical devices — diagnostic X-ray and radiographic imaging systems with a low risk of military diversion — to be exported to Russia without a situational licence, provided appropriate documentation is submitted.
South Korea: Key Developments 2024–2026
The South Korean regime has matured significantly in terms of both scope and enforcement over the past two years.
February 2024 saw the entry into force of the expanded restrictions on vehicles with engines larger than 2.0 litres, rechargeable batteries and heavy equipment — the categories where circumvention through third countries had been most extensively documented.
July 2024 brought the Enforcement Decree amendment establishing an autonomous legal basis for unilateral export controls, decoupled from the need for multilateral regime consensus.
April 2025 saw further expansions of the situational licence list, continuing the pattern of incremental alignment with US and EU practice.
On the enforcement side, the story of the past two years is one of rapidly increasing scrutiny. The Korea Customs Service reported that the volume of illegal car exports from South Korea to Russia surged more than fivefold during 2025, reaching approximately 100 million USD — an increase that occurred after the stricter vehicle restrictions were put in place in 2024, driven by evasion networks using declarations to third countries and the registration of new vehicles as used before shipment. This spike has prompted intensified enforcement activity, with prosecutors and customs officials actively investigating circumvention networks involving routes through China, Kazakhstan and Kyrgyzstan. Criminal convictions for violation of Russia-related export restrictions were handed down in 2025, following the first such cases in 2024.
The Japanese Framework: FEFTA and METI
Japan also operates without a dedicated sanctions statute. Its export restrictions on Russia are implemented under the Foreign Exchange and Foreign Trade Act (FEFTA), with export controls on goods administered by the Ministry of Economy, Trade and Industry (METI). Financial measures fall under the Ministry of Finance (MOF), and the overall foreign policy framework is coordinated by the Ministry of Foreign Affairs (MOFA). This three-ministry structure means that Japan’s Russia-related measures span multiple legal instruments — Cabinet Orders, Ministerial Orders and Ministerial Notices — which must be read together to understand the full scope of restrictions.
Japan joined the like-minded coalition immediately after the February 2022 invasion and was among the first non-Western countries to implement meaningful export restrictions on Russia. As a G7 member, Japan participated directly in the development of the coordinated international response, including the oil price cap mechanism and the Common High Priority Items framework.
The FEFTA’s underlying principle is one of minimum necessary control — the default position is freedom of international transactions, with restrictions imposed only to the extent necessary for peace and security. In practice, the restrictions applied to Russia since 2022 are extensive and have continued to expand.
The key export restrictions for goods exporters are:
The Export Trade Control Order (Appended Table 1) is the primary control list for goods, aligned with Japan’s multilateral regime commitments. Items on this list require a METI licence for export to any destination, and licences are not granted for Russia.
Luxury goods have been subject to an export ban since April 2022, covering alcoholic beverages across a wide range of HS codes (22.03, 22.04, 22.05, 22.06, 2207.10, 22.08), high-end fashion and accessories, jewellery and precious stones, luxury leather goods, high-value artworks, and musical instruments above defined value thresholds.
Vehicles — specifically those with engine displacement exceeding 1,900 cc and all hybrid vehicles — require ministerial approval from METI for export to Russia. In practice, this approval is not granted, making the restriction a de facto ban. This category has been one of the primary targets of documented circumvention activity in Japan.
Heavy construction equipment: dump trucks and bulldozers are subject to export restrictions.
Aircraft engines and radio navigational aid apparatus are subject to export controls specific to Russia.
Chemical and biological weapons precursors: substances usable as raw materials for chemical weapon agents and equipment for their production have been controlled since October 2022, with the scope expanded in February 2023.
The catch-all control reform of October 2025 is the most significant structural change to Japan’s export control system in recent years. Promulgated in April 2025 and entering into force in October 2025, this reform introduced a two-tier classification of items subject to catch-all controls. A new category of “core items” — including certain semiconductors, machine tools and unmanned aerial vehicle components — was established as a higher-scrutiny tier. For these items, a Japanese exporter who voluntarily determines that a significant risk exists of the goods being used in the development of conventional weapons is now required to obtain a METI licence in advance, even if the goods are not on the standard controlled list. Separately, the reform introduced a new notification mechanism under which METI can proactively inform exporters that they must apply for a licence due to identified circumvention risks associated with specific destinations or transaction patterns.
The End User List (外国エンドユーザーリスト) is a METI-maintained reference list of foreign organisations for which concerns regarding involvement in WMD or missile development cannot be eliminated. The list is not an embargo — an appearance on it does not automatically prohibit export — but it activates additional licensing requirements. The list is updated regularly and has been significantly expanded in relation to Russia-linked entities and third-country intermediaries: in February 2025 alone, 42 entities were added, including organisations in China, the UAE, Armenia, Kazakhstan and Kyrgyzstan identified as circumvention nodes.
Penalties under the FEFTA for export violations are substantial: up to ten years’ imprisonment and/or a fine of up to JPY 10 million or five times the value of the transaction, whichever is greater. For corporate entities, fines can reach JPY 500 million or five times the transaction value. METI may additionally impose administrative export bans for up to three years and disqualify individuals from serving as corporate directors for the same period.
Japan: Key Developments 2024–2026
The period from late 2024 through early 2026 has been one of significant evolution in both substance and enforcement for Japan’s Russia sanctions regime.
October 2024 brought the first criminal conviction in Japan for violation of Russia-related export restrictions. A Japanese trading company was fined JPY 5 million, and its Russian national CEO received a three-year prison sentence — suspended for four years — for the unauthorised export of motorcycles and other goods valued at approximately JPY 42 million to Russia, routed through South Korea. The defendants did not contest the charge. The conviction established an important precedent: exporting prohibited goods to Russia via a third country constitutes a violation of Japanese sanctions law. The routing through South Korea provided no legal cover.
December 2024: METI published a detailed explanatory document and accompanying video on its website, setting out red flags for transactions attempting to evade sanctions and providing two illustrative case studies of documented evasion schemes — one of which involved Japanese-branded car parts being exported to Russia through a UAE dealership.
January 2025: 42 entities added to the End User List, targeting circumvention networks in multiple third countries. Simultaneously, 22 Russian entities and 31 entities in third countries — including China, the UAE, Armenia, Kazakhstan and Kyrgyzstan — were added to the export prohibition list.
March 2025: further amendments to the Foreign Exchange Order, with new specifications for controlled goods and technology.
March 2025: a Japanese used car dealership and two employees of an affiliated company were referred for prosecution for the unauthorised export of four luxury vehicles valued at a total of JPY 85 million to Russia between December 2022 and January 2023. The employees pleaded guilty. The foreign beneficial owner of the dealership had left Japan in June 2023 following a METI site inspection.
April 2025: METI announced the catch-all control reform, promulgated in the same month, with entry into force in October 2025.
November 2025: additional amendments to the Export Trade Control Order and the Foreign Exchange Order, updating controlled goods specifications.
December 2025: METI issued a formal warning to Red Baron Co., Ltd. for exporting motorcycles to Russia without the required ministerial approval between 2022 and 2024, using third countries including South Korea as transit points. The company was directed to strengthen internal export control procedures. This case — following the October 2024 criminal conviction in a similar matter — signals that METI is maintaining sustained enforcement pressure even for relatively smaller violations.
How South Korea and Japan Compare
| South Korea | Japan | |
|---|---|---|
| Legal basis | Foreign Trade Act | FEFTA (Foreign Exchange and Foreign Trade Act) |
| Administrator | MOTIE | METI (goods) + MOF (finance) + MOFA (policy) |
| Key mechanism | Situational licence / catch-all list | Export Trade Control Order + catch-all controls |
| Scope of de facto ban | ~1,159+ items on catch-all list for RU/BY | Broad: vehicles >1,900cc, heavy equipment, luxury goods, precursors, and more |
| Catch-all reform | Autonomous legal basis established July 2024 | Two-tier reform in force October 2025 |
| Extraterritorial reach | Limited (no FDP Rule equivalent) | Japanese residents and agents of Japanese companies, worldwide |
| First criminal conviction | 2025 (vehicles) | 2024 (motorcycles, routed via South Korea) |
| Third-country enforcement | Active — prosecution of routes via China, KZ, KG | Active — End User List covers UAE, China, KZ, KG, AM |
| Coordination | Like-minded group, Wassenaar, G20 | G7, like-minded, Wassenaar |
A Note on Third-Country Routes: Why This Matters for Other Exporters
One dimension of the South Korean and Japanese frameworks that deserves explicit attention is their specific relevance for exporters who are not themselves based in either country.
Both Japan and South Korea have been extensively used as transit or circumvention nodes for goods ultimately destined for Russia — and both governments have responded with increasing enforcement attention to these routes. This creates a direct risk for any exporter whose supply chain, distribution network or intermediary relationships touch either country.
The pattern that has emerged from documented enforcement cases is consistent: goods of non-Korean or non-Japanese origin are routed through Korean or Japanese companies, or exported using Korean or Japanese registered entities, to reach Russia. In several documented cases, the goods in question were Japanese-branded or Korean-branded products manufactured elsewhere. The first criminal conviction in Japan involved a company whose CEO was a Russian national operating through Japan. The enforcement actions in South Korea have involved premium vehicles of multiple nationalities being registered as used before transit.
For exporters using distributors or trading companies in South Korea or Japan as part of a supply chain that includes any Russian connection — however indirect — awareness of these frameworks is essential. An exporter who sells legitimately to a Korean or Japanese intermediary cannot assume that their responsibility ends at the point of sale if there are indicators of Russian end-use. Both METI and MOTIE have explicitly warned that due diligence failures in relation to known circumvention risk can constitute a violation.
A Practical Checklist for Exporters
Before proceeding with any transaction where South Korean or Japanese connections may be relevant, work through the following:
- Assess your connections to both jurisdictions. Does your supply chain include components, technology or software of Korean or Japanese origin? Do you use Korean or Japanese trading companies, distributors or agents? Any of these may bring you within the scope of their controls.
- Check the South Korean catch-all list if you export industrial machinery, electronics, batteries, vehicles, semiconductors or related goods. The list now covers approximately 1,159 items and is updated through MOTIE Public Notices.
- Check the Japanese Export Trade Control Order and the catch-all “core items” against your product specifications, including the new higher-scrutiny tier introduced in October 2025 for semiconductors, machine tools and UAV components.
- Check the Japanese End User List maintained by METI. If your buyer, intermediary or any entity in your transaction chain appears on this list, licensing requirements are triggered regardless of the product’s controlled status.
- Check the South Korean Denial List at yestrade.go.kr against your buyer and any intermediaries.
- Assess your intermediaries in third countries. If you use distributors in Central Asia, the UAE, China or other documented transit hubs, verify that they are not on the End User List or the Korean Denial List and that there are no indicators of Russian end-use.
- Verify payment routes before accepting any order. De-risking behaviour by banks applies to transactions with Korean and Japanese sanctions exposure just as it does for EU and US sanctions.
- If your product is permitted under all applicable regimes, ensure your EAC certification is current and valid before shipping. A clean sanctions compliance record does not substitute for missing customs documentation at the EAEU border.
Conclusion
South Korea and Japan are not the most prominent names in the Russia sanctions landscape for most exporters — but they are consequential, increasingly active, and directly relevant to supply chains that extend beyond the familiar EU, US and UK frameworks.
Both countries implemented export restrictions quickly after February 2022, both have expanded those restrictions steadily, and both have moved into active criminal enforcement. The first convictions in both jurisdictions during 2024 and 2025 — and the documented patterns of circumvention they addressed — make clear that these are not paper regimes.
For any exporter whose products, components or distribution arrangements have connections to South Korea or Japan, checking only the most familiar Western frameworks leaves a significant gap. The full compliance picture for Russia now spans at least six independent regimes, and the coordination between them — through the G7, the like-minded group and the Wassenaar Arrangement — continues to tighten.
For a complete overview of the other sanctions regimes in this series, see the posts on EU sanctions, US and UK sanctions, and Canadian and Australian sanctions. If you have questions about how any of these frameworks apply to your specific product or export situation, get in touch with our team.