On June 4, 2025, the U.S. House of Representatives passed the Ukraine Support Act (H.R. 2913) (the “Act”), a broad measure that would, if enacted, (1) impose new Russia-related sanctions, (2) codify and tighten existing U.S. export controls, (3) impose duties of at least 500% on Russian imports and taxation of blocked assets, and (4) authorize additional Ukraine-related security and reconstruction measures.
The bill now moves to the Senate, where its prospects remain uncertain. If enacted, the Act would require the president, “[n]ot later than 15 days” after its enactment and at least every 90 days thereafter, to determine whether Russia or its proxies are waging a war of aggression against Ukraine, refusing to negotiate a peace agreement in good faith, or violating an existing peace agreement. If the President makes an affirmative determination, the Act requires the executive branch to implement specified sanctions, export controls, and duty increases within 15 days.
We summarize the principal trade- and sanctions-related provisions below.
- New Russia-Related Sanctions
Following an affirmative determination, the Act requires the president to impose a broad range of sanctions relating to various aspects of the Russian economy and the full-scale invasion. Under section 317 of the Act, such sanctions encompass property blocking, visa restrictions, and US opposition to certain international financial institution financing that would directly or indirectly benefit sanctioned foreign persons.
The Act requires the President to impose the following sanctions upon an affirmative determination:
- Financial Institutions: Sanctions on at least three of thirteen Russian financial institutions listed in the Act. The Act also provides for the imposition of sanctions on subsidiaries and successor organizations of such financial institutions, as well as additional institutions identified by the President as being “owned or operated” by the Government of Russia.
- Oil and Mining: Sanctions on all Russian entities engaged in the extraction, refinement, or processing of oil, gas, coal, and minerals.
- Russian Government Officials: Sanctions on 22 senior Russian government and military officials identified in the Act, including the Russian President, Prime Minister, Foreign Minister, and Chief of the General Staff. The Act also provides for imposition of sanctions on other senior officials identified by the executive branch as leading a Russian state-owned financial institution or holding a significant role in planning or implementing operations for state intelligence agencies or security services.
- Crimea Tunnel: Sanctions on all foreign persons that knowingly participate in constructing, maintaining, or repairing the Kerch Strait Bridge, or any future tunnel or bridge linking Russia and occupied Crimea.
- Zaporizhzhia Nuclear Power Station: Sanctions on foreign persons who have endangered the integrity and safety of or have undermined Ukrainian operational control of the Power Station since the start of the full-scale invasion. Sanctions will not apply to those who seek to reestablish Ukrainian operational control of the plant.
- Rosatom: Sanctions on Rosatom (i.e., the Russian state nuclear corporation), its subsidiaries, and foreign persons that knowingly engage in significant transactions involving nuclear construction or related services with Rosatom. The President may issue waivers for transactions with Rosatom if the purpose is to produce medical or industrial isotopes.
- Oil Shipping: Sanctions on anyforeign vessel knowingly transporting Russian oil in violation of the Russian oil price cap policy. Sanctions do not apply to those providing provisions to a vessel intended for the safety and care of the crew or the protection of human life aboard the vessel.
- SWIFT: Sanctions on any global financial messaging or communications service provider that continues to service sanctioned Russian financial institutions.
- Sovereign Debt: Prohibition on all transactions by US persons involving Russian sovereign debt, including government bonds.
- Russia-North Korea: Sanctions on any foreign person or financial institution that facilitates the sale of arms and materials from North Korea to support Russia’s war in Ukraine.
- Ukrainian Children: Sanctions on all foreign persons involved in the kidnaping and wrongful patriation of Ukrainian children.
- Codification and Tightening of Existing U.S. Export Controls
Following an affirmative determination, the Act introduces a new Russia-related foreign-direct product rule (“FDPR”) under the Export Administration Regulations (“EAR”). Under the new FDPR, foreign-produced items would be subject to the EAR if they are the direct product of (a) certain technology or software subject to the EAR or produced by a plant or major component of a plant that itself is the direct product of certain U.S.-origin technology or software and (b) destined for Russia or incorporated into or used in the production or development of any part, component, or equipment subject to the EAR and produced in or destined to the Russia. The new FDPR would not apply to (a) items necessarily and ordinarily incident to communications, or items classified as EAR99 or 5A992.c/5D992.c, and which are “subject to a general license issued by the Department of Commerce or Department of Treasury.”
- Duties of at Least 500% on Russian Imports and Taxation of Blocked Assets
Upon an affirmative determination, the Act requires ad valorem duties of at least 500% on all goods and services imported from the Russian Federation into the United States. The measure also requires a 100% tax on any interest or dividends earned by the Russian or Belarusian governments from blocked sovereign assets.
- Additional Ukraine-Related Measures
In addition to sanctions and trade restrictions, the Act includes several Ukraine-focused measures, including:
- War Risk Insurance: War risk insurance for certain vessels transporting goods to or from Ukraine for five years after enactment, including exemptions from certain insurance-related restrictions where ownership criteria are met. The Act also establishes the Insurance for Ukraine Initiative to support economic recovery, investment, and agricultural exports.
- Special Coordinator for Ukrainian Reconstruction: The measure establishes a Special Coordinator for Ukrainian Reconstruction under the secretary of State, which includes coordinating federal agencies, promoting interagency cooperation, and mobilizing private capital. It also creates a Ukraine Reconstruction Trust Fund for Ukraine’s reconstruction, humanitarian aid, economic development, and good governance.
- Waivers: The measure establishes exceptions and a waiver for sanctions under the bill. It exempts visa sanctions when necessary to comply with U.S. international obligations, including complying with the United Nations Headquarters Agreement. It prohibits sanctions on transactions related to humanitarian aid, food, medicine, or U.S. national security, intelligence, or law enforcement activities, and it allows the President to waive sanctions if deemed extraordinarily vital to U.S. national security, with prior notification to Congress.
The authors acknowledge the assistance of Hunter Morgan in the preparation of this post.
