Effective as of 18 April 2023, Ukraine introduced two new sets of personal sanctions against 438 individuals and 254 legal entities, mainly targeting the Russian IT and sports industries.[1] According to President of Ukraine Volodymyr Zelenskyy, the new sanctions package targets, inter alia, Russian IT companies sponsoring terror or providing digital opportunities to continue the Russian aggression against Ukraine.[2]

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; revocation or suspension of licenses and other permits; prohibition on the transfer of technologies and on the rights to objects of intellectual property rights; ban on provision of electronic communication services and use of electronic communication networks; and blocking of access to web resources/services by internet providers. 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 internet holdings — Yandex LLC (yandex.ru, yandex.ua), Rumbler Group LLC (livejournal.com), Rumbler Internet Holding LLC (rambler.ru), VK Company LLC (vk.com, ok.ru, mail.ru), Siberian Internet Company LLC, Gazpromneft-Digital Solutions LLC, etc.
  • Russian IT companies — Production Company “SKB Kontur” JSC, Marvel KT LLC, Softline Trade JSC, Krok Incorporated CJSC, Jet Infosystems JSC, etc.
  • Russian IT companies providing enterprise automation services — Software Products “Sail” LLC/Software Products “Parus” LLC, 1C-Galaktika LLC, Sitronics JSC, Bitrix24 LLC, Gazprom Automation PJSC, etc.
  • Founders and management of the above Russian internet holdings and IT companies — Vladimir Bublik, Oleg Molodykh, Mikhail Srodnykh, Dmitrii Mramorov, Boris Bobrovnikov, etc.
  • Russian sportspersons — figure skaters Aleksandra Boikova and Ilia Averbukh, President of the Russian Triathlon Federation Kseniia Shoigu, football player Igor Akinfeev, swimmer Anton Chupkov, etc.

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. 227/2023 dated 15 April 2023 “On the Decision of the National Security and Defense Council dated 15 April 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 18 April 2023; Presidential Decree No. 228/2023 dated 15 April 2023 “On the Decision of the National Security and Defense Council dated 15 April 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 18 April 2023 (the “Decisions“).

[2] Address of President of Ukraine dated 15 April 2023.


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.