Guide to Countries Embargoed for Export of Sensitive Goods and Trade Restrictions

I. Definition of Sensitive Goods
Sensitive goods generally include, but are not limited to, the following categories:

Military/Defense-Related: Weapons, ammunition, military technology, explosion-proof equipment, etc.

Dual-Use Items: Technologies or products with both civilian and military applications (such as high-precision sensors, drones, encryption software, etc.).

Nuclear and Biological/Chemical-Related: Nuclear materials, biological and chemical agents, and related equipment and technologies.

Advanced Technology: Semiconductors, artificial intelligence, quantum computing, aerospace technology, etc.

Scarce Resources: Rare earth elements, certain minerals, rare plants and animals, etc.

Other: Surveillance equipment and medical drugs (such as anesthetics) involving human rights issues.

II. Major International Embargoes and Restrictions

Wassenaar Arrangement (WA)

Restricted Countries: Exports of military/dual-use items are restricted to countries such as North Korea, Iran, and Syria.

Participating Countries: 42 countries, including the United States, the European Union, and Japan, are required to comply with the agreement list.

US Export Controls (EAR/ITAR)

ITAR (Defense-Related): Prohibits the export of weapons and critical technologies to China, Russia, North Korea, and other countries.

EAR (Commerce Control List): Restricts Entity List companies such as Huawei and SMIC.

UN Sanctions

North Korea: Comprehensive embargo on weapons, luxury goods, energy equipment, etc.

Iran: Restrictions on nuclear technology and ballistic missile-related items.

EU Trade Restrictions

Sanctions on Russia and Belarus in the energy, financial, and high-tech sectors (2022 to present).

III. List of Key Embargoed Countries/Regions (Example)
Country/Region Key Restricted Items Basis
North Korea All military, dual-use, and energy technologies UN Security Council resolutions
Iran Nuclear technology, drones, precision instruments US EAR/EU regulations
Russia Semiconductors, oil and gas equipment, financial services EU-US sanctions
Syria Weapons, surveillance equipment EU Regulation No. 36/2012
China (Specified Entities) High-tech (AI, supercomputers, semiconductors) US EAR Entity List
IV. Export Compliance Recommendations
Screen Trading Partners

Verify whether customers are located in embargoed countries or on entity lists (e.g., the US BIS website, EU sanctions lists).

Commodity Classification and Licensing

Accurately identify the HS code and ECCN (Export Control Classification Number) of goods and apply for necessary export licenses.

Be aware of transshipment risks

Avoid transshipment of goods through third-party countries en route to embargoed countries (e.g., Dubai and Hong Kong may be used as transit points).

Compliance Training

Regularly update the team’s understanding of international sanctions developments (e.g., new regulations following the Russia-Ukraine conflict).

V. Common Risks and Penalties
Legal Risk: Violations of regulations may result in significant fines (e.g., US BIS fines of up to millions of dollars) or criminal liability.

Reputational Risk: Companies may be blacklisted and lose access to international supply chains.

VI. Update Channels
U.S. Department of Commerce Bureau of Industry and Security (BIS) official website: www.bis.doc.gov

EU Sanctions Map: https://www.sanctionsmap.eu

China Ministry of Commerce Export Control Announcement: http://www.mofcom.gov.cn