Effective as of 30 May 2023, Ukraine introduced a new set of personal sanctions against 51 individuals and 220 legal entities.[1]

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

  • Russian providers of offline maps: 2GIS (2GIS Local Search Limited (Cyprus)), Navitel (Navitel s.r.o. (Czech Republic) and LLC “Navitel Ukraine” (Ukraine)) and City Guide (LLC “MIT Geomatics”)
  • Russian food delivery and taxi services: LLC “O2O Holding”
  • Russian producers of unmanned aerial vehicles: LLC “Aerob”, LLC Research and Production Enterprise “Autonomous Aerospace Systems – Geoservice”, LLC “Aerolaboratoriya”/RusAeroLab LLC, etc.
  • Russian military industry enterprises: Open JSC “Specialized Design Bureau “Zenit”, PPJC “Nizhny Novgorod Television Plant named after V. I. Lenin”, etc.
  • Russian companies related to Russian railways: PSJC “Asha Metallurgical Plant”, JSC “Metallservice”, etc.
  • The largest Belarusian machine-building plant: JSC “Railway Trading Company”, JSC “RZhD Logistica”
  • Belarusian radio electronics enterprises: Open JSC “Gomel Design Bureau “Luch”, Open JSC “Managing Company of the Holding “HORIZONT”, etc.

The Decision imposes extensive sanctions, including asset freeze; ban on trade operations; ban on the 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; termination of trade agreement. The particular set of sanctions applicable to each person is set forth in the annexes to the Decision.

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

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. 307/2023 dated 27 May 2023 “On the Decision of the National Security and Defense Council dated 27 May 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 30 May 2023 (the “Decision“).


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.