Effective as of 9 December 2023, Ukraine introduced a new set of personal sanctions against 181 Russian legal entities and 185 individuals (the “Sanctions“), mostly related to the Russian military-industrial complex.[1] In particular, the Sanctions have been imposed on:

  • these following Russian companies:
    • Military-industrial enterprises: Federal State Unitary Enterprise “13th Shipyard of the Black Sea Fleet” of the Ministry of Defense of the Russian Federation, JSC “Kovrov Electromechanical Plant”, PJSC “Lyskovsky Electro-Technical Plant” etc.
    • Machine-building enterprises: LLC Plant of Electric Aggregate Engineering “SEPOZEM” of JSC “Saratov Electric Aggregate Production Association”, JSC “Pavlovsky Machine Building Plant “Voskhod”, OJSC Electromechanical Engineering Plant “Velkont” etc., and
    • Manufacturers and suppliers of electronic components, including for the Russian military industry: LLC “Amitron Electronics”, LLC “VMK”, LLC “NeoTech”, LLC “EMS-Expert”, LLC “Telecom and Microelectronic Industries”, LLC “Radiodetal Postavka” etc.
  • the following individuals:
    • Management and founders of the enterprises associated with the Russian military-industrial complex: Member of the Board of Directors of JSC “Corporation “Tactical Missiles” Mikhail Dmitriev, CEO of LLC “VMK” Dmitrii Rebus, CEO of LLC “NeoTech” Vitalii Genovich, founder of LLC “Amitron Electronics” Valentina Pigareva etc., and
    • Russian citizens that have close ties with Head of the Chechen Republic of the Russian Federation Ramzan Kadyrov: Apti/Apty Alaudinov and Ramzan Tsitsulaev.

The Decision imposes an extensive set of 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; and prohibition on concluding contracts and executing transactions. 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. 813/2023 dated 7 December 2023 “On the Decision of the National Security and Defense Council dated 7 December 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 7 December 2023 (“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.