Ukraine improves its personalised sanctions regime

Ukrainian Presidential Decree No. 82/2019 of 19 March 2019, enacting the resolution of the National Defence and Security Council to review existing and introduce new three-year restrictions (sanctions) to the relevant sanctions list, came into effect on 21 March 2019.  

The new Ukrainian sanction lists are special as they align with new restrictions imposed by Canada and the Unites States against Russia and include persons sanctioned by the above-mentioned countries in March 2019.

848 individuals are on the new sanction list. Three individuals were removed from the individual sanctions list 2018 (includes 1,759 persons). The details of one of the individuals sanctioned were changed (updated).

294 companies are on the new list of sanctioned legal entities. Eight legal entities were removed from the list of sanctioned legal entities 2018. The details of two other legal entities were updated.

It is worth noting that the resolution of the National Defence and Security Council significantly expanded the practice of lifting restrictions on certain persons. Please be reminded that the Ukrainian Sanctions Act specifies in its Article 5(7) that sanctions may be ended by resolution of the authority that issued them, if the sanctions have achieved their desired outcomes. The relevant persons should therefore be expected to have submitted documentary evidence showing that the sanctions achieved their outcomes, providing a basis for the lifting of the same. 

For more details, please contact Asters Partner Oleksandr Onufrienko or Senior Associate Mykola Melnychuk.

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