On 19 March 2019, the President of Ukraine enacted the decision of the Ukrainian National Security and Defense Council (“NSDC“)[1] imposing new and extending existing sanctions against 294 legal entities and 848 individuals.

Extensive sanctions restrictions, including assets freeze, preventing the withdrawal of capital outside of Ukraine and restricting trade operations, were imposed against Russian and foreign companies and individuals that:

  • were involved in the construction of the Kerch Strait Bridge, including Stroigasmontazh LLC, PJSC Mostotrest and JS–° Insitute Giprostroimost – St. Petersburg;
  • distribute publishing products of anti-Ukrainian content, including Publishing House Eksmo LLC, Publishing House Veche LLC and Publishing House Ast LLC;
  • violated Ukrainian legislation on entry and/or exit to/from Crimea;
  • illegally received and used museum collections owned by Ukraine;
  • were involved in an armed attack and seizure of Ukrainian military boats, as well as the illegal detention of Ukrainian sailors; and
  • organized and facilitated elections on the temporarily occupied territories of Donetsk and Luhansk regions and in the Crimea.

The new sanctions list includes PJSC Severstal, PJSC Power Machines, JSC Stroytransgaz, JSC Russian Aircraft Corporation MIG, Shipbuilding Plant Zaliv LLC, PJSC Yaroslavsky Shipbuilding Plant, PJSC Tupolev, EN+ Group PLC and PJSC Mako Holding.

The NSDC also extended the term of certain existing sanctions restrictions, in particular against banks with the Russian state capital (Sberbank PJSC, Prominvestbank PJSC, VTB Bank PJSC and BM Bank PJSC) and Yandex.

The new sanctions are imposed/extended for a period from two to three years.

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] Decree of the President of Ukraine No. 82/2019 dated 19 March 2019 enacting the NSDC Decision dated 19 March 2019 “On Imposition, Cancellation and Amendment of Personal Special Economic and Other Restrictive Measures (Sanctions)“.

Author

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.