Russia Resolution No. 1544 — temporary ban on enriched uranium exports to the United States

Mechanism

Resolution No. 1544 inserts HS code 2844 20 (uranium enriched in U-235; plutonium and their compounds) into Annex 2 of Government Resolution No. 313 of 9 March 2022. Resolution 313 is the framework instrument that operationalises Russia's counter-sanctions export-restriction regime: Annex 1 lists goods banned for export to all "unfriendly states" and Annex 2 lists goods subject to country-specific or licence-conditional restrictions. The November 2024 amendment puts enriched uranium in the latter category, specifically targeting the United States and US-incorporated counterparties, with FSTEC-licensed exemptions as the regulatory release valve.

The Russian government's own framing (government.ru/en/docs/53343) describes the measure as a direct response to the US Prohibiting Russian Uranium Imports Act of 13 May 2024, which bans US imports of unirradiated low-enriched uranium produced by Russia or by Russian state entities (with a DOE waiver window through 2027 and a hard cutoff in 2028). The Russian instrument mirrors the asymmetric structure: a temporary ban with a discretionary licence escape hatch, timed to expire 31 December 2025 — earlier than the US 2028 hard cutoff, providing a renewal/escalation lever each December.

At the time of enactment, Russia (via TENEX/Rosatom) supplied roughly 24% of US nuclear utility enrichment services, the single largest foreign source. The two instruments together are the opening moves of a structural decoupling of the global LEU/HALEU market across the US–Russia axis.

Downstream implications

• US utilities accelerate contracting with Urenco USA (Eunice, NM),

Orano (France), and CENTRUS (Piketon, OH) — capacity-build incentives strengthen on both the US LEU and HALEU sides.

• HALEU supply tightens — Russia had been the only commercial

HALEU source globally, and the November 2024 ban removes the TENEX licence-conditional channel as a backstop. Pressure on the DOE-funded HALEU Availability Program intensifies.

• TENEX/Rosatom's residual EU enrichment contracts (France EDF,

Hungary Paks, Slovakia Mochovce, Czechia Dukovany, Bulgaria Kozloduy) become the relative-value question: are they next on the EU side, and does Russia pre-empt with a sibling export restriction?

• Spot UF6 / SWU pricing premium widens on Western-source

enrichment; URA / URNM ETF beta to enrichment-tier supply shocks materially elevated through 2025.

• Severity 4 is set on (a) the magnitude of the supply share

removed, (b) the structural rather than tactical character of the decoupling, and (c) the optionality the FSTEC licence channel preserves for Russia to escalate further or partially walk back.

Why severity 4 (not 5)

The action is severity 4 rather than 5 because (a) the FSTEC one-off licence channel preserves a non-zero export pathway — several US utilities reportedly continued to receive deliveries under exemption licences through Q1 2025; (b) the 31 December 2025 sunset means the measure is by construction temporary unless renewed; and (c) the US side, having had ~6 months of preparation between the May 2024 import ban and the November 2024 export ban, was already well into substitution contracting. A full embargo without a licence channel would warrant severity 5.

Open questions

• Whether the ban is renewed past 31 December 2025 — the

December 2025 renewal cycle is the next dated decision point and is implicitly tracked by this filing's effective_date / amendment-watch.

• FSTEC licence issuance volume — qualitative reporting through

Q1 2025 suggests material grants; no public registry exists.

• Whether the EU follows the US on a Russian-uranium import

ban — the residual EU TENEX contracts are the largest remaining Western Russian-LEU exposure and the most likely next escalation point on either side.