The Hidden Export Rule Most Companies Miss, with Josh Rodman

Host: Lalo Solorzano and Andy Shiles
Guest(s): Josh Rodman
Published: May 20, 2026
Length: 31:53
Presented by: Global Training Center

Summary

Export compliance is not always as simple as checking an ECCN, screening restricted parties, and moving forward. In this episode, Lalo Solorzano and Andy Shiles speak with Josh Rodman, Senior Attorney with Schulz Trade Law, about a lesser-known export control issue involving Russia, Belarus, and outbound HTS-based controls under Part 746 of the EAR.

Josh explains why Russia and Belarus are different from most export destinations: certain products may trigger export licensing requirements based on their HTS code, even when the product appears to be EAR99 and even when the shipment is not going directly to Russia or Belarus. The bigger concern is diversion risk, especially when goods are shipped to high-risk jurisdictions such as Kazakhstan, the UAE, certain “STAN” countries, or other locations where products may later be transferred.

The conversation also covers routed transactions, USPPI responsibilities, the importance of accurate ECCN and HTS classification, shipper’s letter of instruction documentation, written procedures, customer due diligence, and when companies may need to consider licensing or deeper review before proceeding.

Main Topic / Discussion

This episode focuses on how U.S. exporters can identify and manage export control risks tied to Russia and Belarus, even when they are not selling directly into those countries. Josh Rodman explains that Part 746 of the EAR creates outbound HTS-based controls for certain products destined for Russia or Belarus, or for transactions where there is a significant risk of diversion.

The discussion highlights how exporters can miss this issue if they only rely on ECCN analysis, restricted party screening, or standard export procedures. The hosts and guest also explore routed transactions, domestic sales that may later become exports, distributor risk, documentation practices, and the need for written compliance procedures and training.

Key Takeaways

• Russia and Belarus are unique because certain export controls are tied to outbound HTS codes, not only ECCNs.

• An EAR99 product may still require deeper review if the HTS code appears under Part 746 and there is a risk of diversion to Russia or Belarus.

• Exporters should not rely solely on customer assurances, especially when working with new distributors in higher-risk jurisdictions.

• Routed transactions do not eliminate the U.S. seller’s responsibilities; the USPPI should provide accurate ECCN information through the SLI.

• Written procedures, trained staff, accurate classifications, customer diligence, and documentation can help protect companies when export risks arise.

• Export opportunities remain strong, but companies need a solid compliance foundation before pursuing higher-risk international sales.

Resources & Mentions

• Global Training Center
• Schulz Trade Law
• International Compliance Professionals Association
• Bureau of Industry and Security
• 15 CFR Part 746 – Embargoes and Other Special Controls

Credits

Host:
Lalo Solorzano
Andy Shiles

Guest(s):
Josh Rodman

Producer:
Lalo Solorzano

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