Powered by
In 2014 Ukraine adopted its first sanctions law, which stipulated both sectoral and personal sanctions. Twenty-four (24) specific sanctions were provided, including blocking assets, restricting trade operations, preventing capital withdrawal outside of Ukraine, etc.
Moreover, the legislator determined the possibility of imposing “other sanctions list which correspond to the principles of their imposition” (the 25th sanction). This fact actually makes the list of sanctions non-exhaustive.
The sanctions policy has undergone a rapid evolution following the full-scale invasion of the Russian Federation into Ukraine in February 2022.
After February 2022, new sanctions were introduced:
However, the most significant change was the introduction of an exceptional sanction – the recovery of assets into the state budget (assets nationalization), which may be applied only during the period of martial law.
After February 2022, new sanctions were introduced:
However, the most significant change was the introduction of an exceptional sanction – the recovery of assets into the state budget (assets nationalization), which may be applied only during the period of martial law.
For the first time, personal sanctions were imposed in Ukraine in 2015. At that time, Russian and Russia-related politicians, artists, banks, companies, and mass media became subject to restrictions (Joseph Kobzon, Ramzan Kadyrov, Sergei Shoigu, Gazprombank etc.).
Since 2015 until 2021 the President of Ukraine put into effect forty-five (45) decisions on sanctions imposition.
9 070 persons were listed in 2015-2021. Among them were:
As a result, currently 7 126 legal entities and 10 085 individuals are subject to restrictions.
Industry, logistics, communications, energy, science and education, as well as the sphere of public and military groups and government structures have been affected.
The russian leadership, the leadership of the military-industrial complex, the occupying “authorities”, oligarchs, security forces, propagandists and other persons, who supported aggressive actions, are at the top of the sanctions lists.
In addition, the High Anti-Corruption Court has already considered forty-seven (47) lawsuits on the imposition of an exceptional sanction – assets nationalization (recovery of assets into the state budget).
This sanction’s peculiarity is also apparent in its application. It shall be applied by the High Anti-Corruption Court following the lawsuit of the Ministry of Justice of Ukraine. Assets owned or controlled by individuals or legal entities, whose actions contribute to the aggression, are subject to nationalization. The mere sign of affiliation with the Russian roots is enough for the court to confiscate the assets.
Funds in the amount of at least $2.1 million
Shares in the authorized capitals of 63 companies
178 real estate assets
88.89% of shares in First Investment Bank JSC
308 vehicles
537 cultural values worth €18 million
24 land plats
This procedure prescribes application to the bodies involved in sanctions imposition with a request to lift them. The authorized bodies are:
The decree of the President of Ukraine on sanctions imposition may be challenged before the Supreme Court. The process is complicated by the need to have access to classified information.
Chambers and Partners published the first-ever overview of Ukraine's sanctions policy, prepared by the lawyers of VB Partners
Lifting the National Security Council’s sanctions imposed on both foreign companies and individuals in court. We were one of the first to achieve the lifting of sanctions imposed by Ukraine on an EU company.
Lifting the National Security Council’s sanctions imposed on both foreign companies and individuals through an administrative procedure. The legislation doesn’t provide for a detailed procedure in respect thereof. VB Partners forms and develops such practice.
Support of disputes regarding the confiscation of property in a sanctioned manner. The possibility of nationalizing the assets of Russian officials arose after a lawsuit filed by the Ministry of Justice. However, it also affects Ukrainian business, which was acquired from the Russian federation’s residents before the war. We prove that the assets belong to real Ukrainian businesses and non-residents and are not subject to nationalization.
