By making the first entry to the national sanctions list, the Czech Republic has taken another step in its efforts to use its sanctions powers to respond more rapidly to the Russian invasion of Ukraine.

Earlier this year, the Czech Republic adopted the Sanctions Act, which implements the process for including entities on the Czech national sanctions list or the EU sanctions list and the rules for adopting national restrictive measures against certain entities for actions sanctionable under the relevant EU regulation. The aim of the Sanctions Act is to respond to situations where a restrictive measure cannot be achieved at the EU level or where the length of the approval process does not allow for a flexible response to the situation.

The powers under the Sanctions Act were deployed  on 26 April 2023, when the Czech Government placed the head of the Russian Orthodox Church, Vladimir Mikhailovich Gundyayev, better known as Patriarch Kirill, on the Czech national sanctions list for supporting the Russian invasion of Ukraine. The restrictive measures consist inter alia of an asset freeze, a ban on entering the territory of the Czech Republic and a prohibition on undertaking any financial transactions through Czech systems, and all such measures are effective immediately. The leader of the Russian Orthodox Church and a supporter of the Russian President Vladimir Putin has not been put on the EU sanctions list yet as some of the Member States objected to his inclusion during the discussions on the 6th EU sanctions package.

While this designation of Patriarch Kirill may not have a material impact on business dealings, it does point to the increasingly complex sanctions landscape that businesses have to navigate in the EU.  We have seen an increasing number of unilateral measures introduced by EU Member States, going beyond the EU measures.  It is also a reminder that even with a common EU sanctions regime, because licensing, administration and enforcement of the measures sit with the 27 EU countries, we commonly witness 27 flavours of the same sanctions measures.  Understanding the national perspective is key for businesses to ensure compliance with EU measures.


Kristína Doupal heads the Firm’s International Commercial & Trade Department in Prague, focusing on trade and commercial law matters. She advises clients in relation to a range of trade and commercial law issues, litigation and arbitration, as well as regulatory proceedings.