Effective as of 16 May 2023, Ukraine introduced five new sets of personal sanctions against 502 individuals and 860 legal entities.[1]

The sanctions affect the following categories of persons, among others:

  • Russian defense industry companies: LLC “69th Repair Plant of Rocket and Artillery Weapons”, LLC “Spetsvoenprom”, PJSC “Kirov Plant “Mayak”, etc.
  • Russian and Belarusian engineering enterprises: JSC “Moscow Machine-Building Enterprise named after V.V. Chernyshev”, JSC “Kazan Compressor Machine Building Plant”, Open JSC “Gomel Plant of Machine Tools and Assemblies”, etc.
  • Russian and Belarusian radio electronics companies: PJSC “Tambov Plant Elektronpribor”, Open JSC “Gomel Radio Plant”, LLC “Ural Radiostations “, etc.
  • Russian aerospace and science institutions: State Corporation for Space Activities “Roscosmos”, JSC “GLONASS”, Federal State Unitary Enterprise State Research Institute of Civil Aviation, etc.
  • Russia’s national postal service provider: JSC “Post of Russia”
  • An extensive number of foreign companies used by Russian businesses for ownership of businesses and assets in Ukraine (in many cases, the foreign SPVs were used to hide links to Russian or sanctioned beneficiaries)
  • A number of Russian and Ukrainian business owners and their family members suspected inhaving close ties with the Kremlin regime and/or supporting the Russian aggression against Ukraine: Vladimir Lukianenko, Vadim Giner, Olga Babakova/Le Brun, Irina Babakova, etc.
  • Chinese companies involved in the trade of electronics and the supply of unmanned arial vehicles to Russia
  • Indian assault rifle manufacturing facility: IndoRussian Rifles Private Limited
  • Russian media companies and TV channels: LLC “STS Media”, LLC “National Sports TV Channel”, LLC “TV Company Pyatnitsa”, etc.
  • Russian museums

The Decisions impose extensive sanctions, including asset freeze; ban on trade operations; ban on transit of resources, flights and transportation within the territory of Ukraine; suspension of the performance of economic and financial obligations; restriction on the exit of capital from Ukraine; prohibition on participating in privatization and lease of state property; revocation or suspension of licenses and other permits; prohibition on the transfer of technologies and on the rights to objects of intellectual property rights; ban on securities transactions; suspension of financial transactions; and prohibition on conclusion of contracts and execution of transactions. The particular set of sanctions applicable to each person is set forth in the annexes to the Decisions.

The full lists of individuals and legal entities subject to sanctions are set forth in the annexes to the Decisions.

Any party dealing with persons on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.


[1] Presidential Decree No. 275/2023 dated 12 May 2023 “On the Decision of the National Security and Defense Council dated 12 May 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”,  effective from 16 May 2023; Presidential Decree No. 276/2023 dated 12 May 2023 “On the Decision of the National Security and Defense Council dated 12 May 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 16 May 2023; Presidential Decree No. 277/2023 dated 12 May 2023 “On the Decision of the National Security and Defense Council dated 12 May 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 16 May 2023; Presidential Decree No. 279/2023 dated 12 May 2023 “On the Decision of the National Security and Defense Council dated 12 May 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 16 May 2023; Presidential Decree No. 280/2023 dated 12 May 2023 “On the Decision of the National Security and Defense Council dated 12 May 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 16 May 2023 (“Decisions“).

Author

Hanna Shtepa is a Counsel heading the International Commercial & Trade (ICT) practice in the Kyiv office of Baker McKenzie. The practice is ranked Tier 1 by Legal 500 EMEA. She specializes in international trade restrictions, economic sanctions and export controls compliance, structuring international supplies of goods and services, anti-dumping investigations, public procurement regulations, trade and general compliance, legal regime and restrictions related to temporary occupied territories and business operations during the military state. She also has extensive experience in project finance, focusing on renewable and conventional energy, financial restructuring, sovereign and municipal finance, nuclear liability. Hanna is ranked as Next Generation Partner for International Trade and Energy and recommended as a Rising Star in Banking, Finance and Capital Markets by Legal 500 EMEA 2020-2022. Ms. Shtepa holds her LL.M. in International Commercial Arbitration Law from the Stockholm University, Stockholm, Sweden.