Effective as of 04 April 2023, Ukraine introduced two new sets of personal sanctions against 273 individuals and 380 legal entities, mainly targeting Russian public officials and the Russian military industry.[1]
The Decisions impose 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; ban on acquiring title to land plots. The particular set of sanctions applicable to each person is set forth in the annexes to the Decisions.
The sanctions affect the following categories of persons, among others:
• Russian state authorities — The Federation Council of the Federal Assembly of the Russian Federation, the Finance Ministry of the Russian Federation, the Federal Security Service of the Russian Federation, the Federal Financial Monitoring Service, the Main Centre for Special Technologies of the General Staff of the Armed Forces of the Russian Federation, the Federal Guard Service of the Russian Federation, etc.
• Russian enterprises operating in the military industry and instrument engineering, radio electronics and oil companies, including, inter alia, JSC “53 arsenal”, JSC “Cheboksary production association named after V.I. Chapaev”, JSC “Information satellite systems” named after academician M.F. Reshetnev”, JSC “Plant “Plastmass”, JSC “Volzhsk electromechanical plant”, JSC “Scientific and production enterprise “Kvant”, LLC “Taimyrneftegaz-Port” and JSC “Rosneftegaz”
• Swiss and UAE companies facilitating the transfer of sensitive technologies and equipment to the Russian Federation
• The UAE company SUN Ship Management (D) Ltd related to the state-owned Russian shipping company Sovcomflot
• An Iranian company engaged in the development of unmanned aerial vehicles (UAVs) — Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jihad Organization
• The top management of certain Iranian companies involved in UAV manufacturing
• Russian citizens serving as public officials, military commanders and top management of Russian enterprises, including, inter alia, Igor Babushkin, Veniamin Kondratiev, Anton Alikhanov, Natalia Budarina, Petr Kononenko, Vladimir Iarmoliuk, Sergei Karakaev and Nikolai Parshin
• The ex-CEO and ex-owner of Ukrainian enterprise Motor Sich, Viacheslav Boguslaev
The full lists of individuals and legal entities 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. 191/2023 dated 01 April 2023 “On the Decision of the National Security and Defense Council dated 01 April 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 04 April 2023; Presidential Decree No. 192/2023 dated 01 April 2023 “On the Decision of the National Security and Defense Council dated 01 April 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 04 April 2023 (the “Decisions“).
