With effect from 27 May 2022, a new set of sanctions was introduced by the Security and Defense Council of Ukraine (NSDC) against the following individuals and legal entities:1

  • Aleksey Likhachev – director general of Rosatom State Atomic Energy Corporation (the Russian Federation)
  • Vladimir Yevtushenkov – shareholder of Sistema Public Joint Stock Financial Company (the Russian Federation)
  • Sistema Public Joint Stock Financial Company – business conglomerate in the Russian Federation (telecommunications, retail, high technology, logging and wood processing, pharmaceuticals, medical services, agriculture, energy, and finance)
  • ITIS LLC – supplier of space communication stations for the Armed Forces of the Russian Federation
  • Kronshtadt Group JSC – manufacturer of unmanned aerial vehicles in the Russian Federation
  • RF JSC – bank in the Russian Federation
  • International Reserve Bank JSC (former Sberbank JSC) – Russia-owned bank in Ukraine (its corporate rights, debt claims and financial assets are being expropriated under the Law of Ukraine “On the Basic Principles of Forced Expropriation in Ukraine of Property of the Russian Federation and Its Residents” adopted back in March 2022)

The sanctions include blocking of assets, restriction on the exit of capital from Ukraine, ban on trade operations and the transit of resources, suspension of the performance of economic and financial obligations, etc., with a unique set of sanctions applicable to each sanctioned person.

This is the first listing that may fall under expropriation following approval of the new rules on expropriation of the sanctioned persons’ blocked assets (for more details please see recent amendments to the Ukrainian sanctions).

Any counterparty dealing with entities or individuals on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.


1Presidential Decree No. 362/2022 dated 24 May 2022 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 27 May 2022; Presidential Decree No. 363/2022 dated 24 May 2022 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 27 May 2022; Presidential Decree No. 364/2022 dated 24 May 2022 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),'” effective from 27 May 2022.(all decisions together referred to as “Decisions”)

Author

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.