On 9 June 2022, Decree No. 401/2022 has become effective, bringing into force a Resolution passed by the National Security and Defence Council to impose individual, special economic and other restrictions (sanctions). The sanctions have been introduced for an indefinite period and apply to certain entities.
Decree №401/2022 has imposed sanctions on 261 higher education institutions in Russia and their rectors. While the restrictions imposed on Russian universities are limited to the termination of cultural exchanges, scientific cooperation, educational and sports contacts, and entertainment programmes with foreign states and legal entities, their managers (rectors) have become subject to a much wider range of restrictions, including the freezing of assets.
Please be reminded that the sanction involving the freezing of assets has been changed recently as the Law of Ukraine on Sanctions was amended by Law of Ukraine No. 2257-IX ("Law No. 2257"), amending certain legislative instruments of Ukraine to improve the efficiency of sanctions related to certain individuals' assets and dated 24 May 2022.
Among many other amendments, Law No. 2257 allows courts to impose an entirely new sanction on individuals whose assets have been frozen, entailing the forfeit to the State of assets owned by an individual or a legal entity, including any assets in respect of which such individual or legal entity can, either directly or indirectly (through other individuals or legal entities), take measures that are akin to the right to dispose of the same.
Accordingly, the sanctions may further expand to include the assets of controlled entities.