Effective as of 21 February 2023, Ukraine introduced sanctions against Moscow Stock Exchange MMVB-RTS PJSC and 333 individuals, mainly the top management of Russian banks and the Russian subsidiaries of foreign banks.[1] According to the Ministry of Economy of Ukraine, the sanctions package is aimed at increasing pressure on the Russian banking system. Specifically, the sanctions target bank managers working for the Russian military-industrial complex and servicing the Russian occupation forces.[2]

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; prohibition on the transfer of technologies and on the rights to objects of intellectual property rights; deprivation of state awards of Ukraine; and ban on acquiring title to land plots.

The full lists of individuals subject to sanctions are set forth in the annex to the Decision.

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. 82/2023 dated 19 February 2023, “On the Decision of the National Security and Defense Council dated 19 February 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)’,” effective from 21 February 2023 (“Decision“).

[2] Press release of the Cabinet of Ministers of Ukraine dated 20 February 2023.


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.