On 29 May 2023, the Ukrainian Parliament approved the decision of the National Security and Defense Council of Ukraine to introduce sectoral special economic and other restrictive measures (sanctions) against the Islamic Republic of Iran.[1]

The sanctions will apply for 50 years and provide for the following:

  • prohibition on trade operations with military and dual-use goods with residents of the Islamic Republic of Iran — if the international transfers of such goods are subject to the controls in Ukraine
  • prohibition on trade operations with services related to the supply, sale, transfer, production or use of military and dual-use goods with residents of the Islamic Republic of Iran — if the international transfers of such goods are subject to the controls in Ukraine
  • ban on the transit of resources, flights and transportation within the territory of Ukraine related to the operations specified in paragraphs (i) and (ii) above by residents of the Islamic Republic of Iran
  • suspension of the performance of financial and economic obligations under the operations specified in paragraphs (i) and (ii) above in favor of residents of the Islamic Republic of Iran
  • restriction on the exit of capital from Ukraine by residents of the Islamic Republic of Iran
  • prohibition on the transfer of technologies and on the rights to objects of intellectual property rights to the residents of the Islamic Republic of Iran
  • prohibition on investments in or in favor of the Islamic Republic of Iran
  • suspension of the service of electronic means of payment (including transfers, settlements and cash withdrawals) issued by the Islamic Republic of Iran
  • cancellation of the registration by the National Bank of Ukraine of: (i) the international payment system — if its operator is the Islamic Republic of Iran; (ii) a participant of the international payment system — if the operator of the international payment system is the Islamic Republic of Iran; and (iii) a participant (resident of the Islamic Republic of Iran) of the international payment system — if the operator of the international payment system is a resident of Ukraine

[1] Presidential Decree No. 308/2023 dated 27 May 2023 “On the Decision of the National Security and Defense Council dated 27 May 2023 ‘On Imposing Sectoral Special Economic and other Restrictive Measures (Sanctions) against the Islamic Republic of Iran'”, effective from 29 May 2023.

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.