🇨🇳Restrictions on goods in Chinese banks

Lawyer, Family Office

Chinese banks have become one of the tightest chokepoints in Russia's foreign trade. Since the start of 2024, lenders from the largest state institutions down to small regional players have refused or stalled payments tied to entire categories of goods, screening each transaction by the commodity code on the invoice. The tables on this page record which goods specific banks have flagged, and the reason they behave this way sits almost entirely in Washington.

Why a Chinese bank cares about a Russian invoice

The trigger is U.S. Executive Order 14114, signed on 22 December 2023. It lets OFAC sanction any foreign financial institution that conducts or facilitates a significant transaction, or provides any service, involving Russia's military-industrial base. The bank need not act knowingly, and the transaction itself needs no U.S. nexus. A correspondent relationship in dollars is enough to put the institution's access to the U.S. financial system at stake.

OFAC widened the net on 12 June 2024 by redefining Russia's military-industrial base to cover every person already designated under Executive Order 14024. That swept in thousands of ordinary Russian companies and banks rather than defence firms alone, so a Chinese bank now assumes that almost any sanctioned Russian counterparty can carry secondary-sanctions exposure.

Everything turns on dollar clearing. A mid-sized Chinese bank reaches the dollar through a correspondent network that runs through New York, and losing it would cut the bank off from most of world trade. Set against that, the revenue from any single Russian client is trivial, which is why the threat bites even when no payment ever touches the United States.

How the 2024 freeze unfolded

The first shock came in February 2024, when Zhejiang Chouzhou Commercial Bank, the main settlement channel for Russian importers, halted all transactions with Russia and Belarus across every system: SWIFT, the Russian SPFS and China's own CIPS. Within weeks the three largest state banks, ICBC, China Construction Bank and Bank of China, stopped accepting payments from sanctioned Russian institutions.

Business then migrated to smaller and border-region banks, which tightened their own rules each time U.S. enforcement signalled a new round. The result is the uneven map captured below: a payment that one bank clears without comment, another rejects on sight, and the same bank may change its position from one quarter to the next.

The list behind the lists: HS codes

The codes the banks watch follow the Common High Priority List, roughly fifty six-digit HS codes that the United States, the EU, Japan and the UK jointly treat as critical to Russian weapons programmes. The list runs across four tiers, with the top tiers covering integrated circuits and radio-frequency modules recovered from missiles and drones in Ukraine. Most entries are dual-use electronics, and many overlap with goods under EU sanctions. HS heading 8471, which appears in the tables below, simply means computers and data-processing units.

What follows is what individual banks have actually blocked or restricted, drawn from payment practice rather than published policy. Banks almost never announce these rules, so treat the lists as a working snapshot that each institution keeps adjusting to its own appetite for risk.

Zhejiang Chouzhou Commercial Bank (CZCB)

Huaxia Bank

Goods under EU sanctions, as well as related to:

• Energy industry
• Mining industry
• Chemical industry
• High technologies
• Electronic devices
• Media
• Machines with electronic components

Zhejiang Mintai Commercial Bank

China Everbright Bank

Goods under EU sanctions

What it means for cross-border trade

For a company moving goods between China and Russia, the restriction is rarely absolute. Payments shift to smaller regional banks, to branches in border cities, or to third-country intermediaries and payment agents, each adding cost and fragility. Settling in renminbi through CIPS rather than dollars helps at the margin, yet a Chinese bank still fears the reach of EO 14114 on a yuan payment, because the threat is to its correspondent network. Routine commercial flows, such as ordinary payments to Chinese suppliers, usually pass unless a flagged code appears on the invoice.

Documentation now decides outcomes. Banks ask for contracts, end-user details and the exact HS code before they release funds, and a single line item in a sensitive chapter can freeze the entire payment. Holding the account through a company registered in China does not remove the screening, because the commodity code, not the account holder, drives the decision.

The European Union runs a parallel track. Its 19th package in late 2025 added microelectronics, propellant chemicals and military-grade metals to dual-use controls, and the 20th package, adopted on 23 April 2026, extended export restrictions to entities in third countries that re-route controlled goods. The two regimes reinforce each other, since an item caught by the EU dual-use list usually sits on the U.S. priority list as well.

Where this is heading

The secondary-sanctions framework remains fully in force in 2026, and Chinese and Turkish banks keep tightening rather than relaxing their screening. Enforcement has moved from blunt refusals toward selective, code-by-code filtering, so the workable channels keep narrowing and shifting. Any list of restricted goods is a snapshot useful for planning, never a substitute for confirming the current position with the bank.