On 10 September 2022, a new set of personal special economic and other restrictive measures (sanctions) became effective (“Decision“).1

The Decision imposes 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 of participation in privatization and leasing of state property, cancellation of visas and licenses, entry bans, etc., upon 606 individuals — Russian politicians and officials — as follows:

  • Twenty-eight members of the Security Council of Russia
  • Forty-four members of the Federation Council of Russia
  • Four hundred and twenty-four deputies of the State Duma of Russia

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

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

1. Presidential Decree No. 637/2022 dated 7 September 2022 “On the Decision of the National Security and Defense Council dated 7 September 2022 “On Amending and Imposing of Personal Special Economic and other Restrictive Measures (Sanctions),” effective from 10 September 2022.


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.