Complying with US sanctions on Russia can be complex and costly, as companies must ensure they do not engage in prohibited activities and maintain documentation of their compliance efforts. This may involve researching the ownership structure and business dealings of suppliers and conducting due diligence before entering into business relationships. To prove sanctions compliance, companies must also be able to track the provenance of goods, which can be challenging due to the inaccuracy of data and the use of email and PDF attachments. To lower the cost of compliance, companies may need to adopt novel approaches that go beyond traditional methods.

The Commodity Control List (CCL) is a list of items that are subject to export controls promulgated by the U.S. Department of Commerce in accordance with the Export Administration Regulations (EAR). The CCL is divided into ten categories, further subdivided into individual commodity classifications.