Effective as of 7 February 2023, Ukraine introduced sanctions against 200 Russian legal entities operating in the Russian nuclear industry.[1] The sanctions package, according to the President of Ukraine Volodymyr Zelenskyy, is aimed to support the efforts of the Ukrainian diplomats in extending the international sanctions against the Russian nuclear sector.
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, as well as public and defense procurement; ban on securities transactions; termination of trade agreements and joint projects; prohibition on the transfer of technologies and on the rights to objects of intellectual property rights; and prohibition on concluding contracts and executing transactions. Among others, the sanctions affect the following Russian legal entities:
- State Atomic Energy Corporation and its subsidiaries
- Atomstroyexport JSC – exporter of nuclear power equipment and service
- Rusatom Energo International JSC – manager of foreign nuclear projects
- Atomenergoproject JSC – general contractor and designer of nuclear power plants
- Production Association ‘Mayak’ Federal State Unitary Enterprise – manufacturer of nuclear weapons parts
- Zaporozhye NPP Operating Organization JSC and Zaporozhye NPP Federal State Unitary Enterprise – legal entities involved in operation and management of the Zaporizhzhia Nuclear Power Plant located in Enerhodar (the nuclear plant was occupied by Russia and is since then is held under the Russian control)
- Baltic NPP JSC – nuclear power plant under construction in Kaliningrad region (Russia)
The full lists of legal entities subject to sanctions are set forth in the annexes to the Decision.
This is the first set of sanctions against the Russian nuclear sector, and another package is expected shortly.
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. 57/2023 dated 5 February 2023, “On the Decision of the National Security and Defense Council dated 5 February 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)’,” effective from 7 February 2023 (“Decision“).
