On 20 October 2022, a new set of personal special economic and other restrictive measures (sanctions) became effective (“Decisions“)[1].

The Decisions impose extensive sanctions restrictions, including asset freezes, restriction on the exit of capital from Ukraine, suspension of the performance of economic and financial obligations, a ban on trade operations, prohibition on participation in privatization and defense procurement as well as securities transactions, a ban on increasing the size of the charter capital of related companies (with a share of 10%), termination of trade agreements and joint projects, cancellation of visas and licenses, and entry bans, etc., upon the following legal entities and individuals:

1,374 legal entities including the following:

  • Russian and Russia-related companies (e.g., the Russian Alfa-Bank and associated companies, the Russian Direct Investment Fund, Rostelecom, RusHydro, Alrosa, Rosgosstrakh, insurance and financial companies associated with VTB Sberbank, RTS- holding, Sogaz, and the Croatian companies T.G.A. D.O.O. za Trgovinu i Usluge and Katina D.O.O)
  • Russian and Belarusian state bodies and state-owned companies (e.g., the federal state budgetary enterprise Special flight unit Rossiya of the administrative department of the president of the Russian Federation, the Kazan Helicopter Plant, the Admiralty Shipyards, Kamaz, and Sukhoi Civil Aircraft, and the Belarusian State Military Industrial Committee of Belarus and OKB TSP and Defense Initiatives)

2,507 individuals, including Russian and non-Russian citizens:

  • Russian propagandists and artists (e.g., Vladimir Soloviev/Solovyov, Olga Skabeyeva and Tina Kandelaki)
  • Russian businessmen and oligarchs, including those close to Vladimir Putin (e.g., Vladimir Lisin, Leonid Mikhelson, Gennadii Timchenko, Suleiman Kerimov, Mikhail Prokhorov, Leonid Fedun, Dmitrii Rybolovlev, Iurii Kovalchuk, Arkadii, Boris and Igor Rotenberg, Said Gutseriev, Elena Baturina, Evgenii Kasperskii, Roman Abramovich[2], Tatiana Bakalchuk, Oleksiy Mordashov and Evgeniy Giner, Yevgeniy Pryhozhyn, Oleg Tinkov,  Oleksandr Yanukovych)
  • Top management of the Russian armed forces and military commanders (e.g., Dmitrу Surovich, Miкhail Mizintsev)
  • Representatives of occupation administrations and leaders of illegal armed forces (e.g., Yevhen Balytskyi, Volodymyr Saldo)
  • Belarusian officials and military leaders (e.g., Viktor Khrenin, Aleksandr Volfovich/Volfovych)

The full lists of persons subject to sanctions are set forth in the annexes to the Decisions.

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. 726/2022 dated 19 October 2022 “On the Decision of the National Security and Defense Council dated 19 October 2022 “On Amending and Imposing of Personal Special Economic and other Restrictive Measures (Sanctions),”” effective from 20 October 2022; Presidential Decree No. 727/2022 dated 19 October 2022 “On the Decision of the National Security and Defense Council dated 19 October 2022 “On Amending and Imposing of Personal Special Economic and other Restrictive Measures (Sanctions),”” effective from 20 October 2022.

[2] Sanctions will apply once the procedure for the exchange of prisoners and dead bodies due to the armed aggression of the Russian Federation against Ukraine is completed.


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.