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 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.