On 4 February 2020, a  decision [1] of the Cabinet of Ministers of Ukraine was officially published revoking all special economic sanctions imposed by the Ministry of the Development of Economy, Trade and Agriculture of Ukraine (MEDT) prior to 7 February 2019. According to the press release from the Minister of the MEDT (Tymofiy Mylovanov), the sanctions were lifted with respect to about 27,000 companies (both foreign and Ukrainian). The decision enters into effect on 6 March 2020.

Before 7 February 2019, the MEDT had authority to impose special economic sanctions restricting cross-border operations and payments by certain foreign and Ukrainian companies. Since 2014, many Russian companies have been added to the sanctions list by MEDT for violation of the Ukrainian laws relating to Crimea and the temporary occupied territories in the East of Ukraine.

This decision of the government does not affect the sanctions imposed by decisions of the National Security and Defense Council of Ukraine.

Additional notes

This LEGAL ALERT is issued to inform Baker McKenzie clients and other interested parties of legal developments that may affect or otherwise be of interest to them. The comments above do not constitute legal or other advice and should not be regarded as a substitute for specific advice in individual cases.

[1] Resolution of the Cabinet of Ministers of Ukraine No. 1180 dated 4 December 2019 “On Cancellation of the Special Sanctions Imposed under Article 37 of the Law ‘On Foreign Economic Activities.‘”


Hanna Shtepa is a Senior Associate of the Kyiv office of Baker McKenzie specializing in economic sanctions, export controls, international supplies of goods and services, public procurement regulations. She has significant experience on advising clients on supplies to Ukraine, participation in Ukrainian public procurement tenders, special regime of trade and business activities in the Crimea and uncontrolled territories in the East of Ukraine, Ukrainian sanctions restrictions against Russia. Hanna is experienced in drafting and negotiation of supply contracts, including procurement contracts for public needs, trade compliance policies and trade finance agreements. Hanna held a number of training and presentations for Ukrainian banks and corporate clients on compliance with Ukrainian sanctions and special trade regimes with the Crimea and uncontrolled territories in the East of Ukraine. She is one of the contributors to Baker McKenzie sanctions blog.