Effective as of 14 February 2023, Ukraine introduced sanctions against 200 individuals, mainly Russian politicians, officials, managers and employees of state-owned nuclear enterprises.[1] This became the second sanctions package against the Russian nuclear sector in response to the ongoing occupation of the Zaporizhzhia Nuclear Power Plant by Russia.

The Decision imposes 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, as well as public and defense procurement; ban on securities transactions; termination of trade agreements and joint projects; prohibition on the transfer of technologies and on the rights to objects of intellectual property rights; cancellation of visas and entry bans; deprivation of state awards of Ukraine; and ban on acquiring title to land plots. Among others, the sanctions affect the following individuals:

  • Iurii Ushakov – assistant to the president of the Russian Federation for foreign policy affairs
  • Larisa Brycheva – assistant to the president of the Russian Federation, head of the State Legal Department of the President of the Russian Federation
  • Igor Borovkov – head of staff of the Board of the Military-Industrial Commission of the Russian Federation
  • Ivan Kamenskikh – member of the Board, first deputy CEO, director of the Directorate for the Nuclear Weapons Complex at Rosatom State Atomic Energy Corporation
  • Oleg Shubin – director of the Department for the Development and Testing of Nuclear Weapons and Military Power Plants at Rosatom State Atomic Energy Corporation
  • Aleksei Ferapontov – deputy head of the Federal Service for Ecological, Technological and Nuclear Supervision (Rostekhnadzor)
  • Viacheslav Ruksha – deputy general director, director of the Directorate of the Northern Sea Route at Rosatom State Atomic Energy Corporation
  • Yurii Сhernichuk – so-called ‘director’ of the operating organization of the Zaporizhzhia Nuclear Power Plant

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. 75/2023 dated 12 February 2023, “On the Decision of the National Security and Defense Council dated 12 February 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)’,” effective from 14 February 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.