Effective as of 21 March 2023, Ukraine introduced a new set of personal sanctions against 300 individuals and 141 legal entities with the aim of targeting the Russian military industry as well as Iranian, Syrian and UAE persons contributing to the Russian aggression against Ukraine.[1]

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; revocation or suspension of licenses and other permits; prohibition on the transfer of technologies and on the rights to objects of intellectual property rights. A particular set of sanctions applicable to each sanctioned person is set forth in the annexes to the Decision.

Among others, the sanctions affect the following categories of persons:

  • Russian legal entities involved in the Russian military industry and their management —JSC “Concern “Kalashnikov”, Joint-Stock Society “Aerospace defence concern “Almaz-Antey”, JSC “Automobile plant “Ural”, JSC “Plant “Universalmash”, etc.
  • Enterprises located on the temporarily occupied territories of Ukraine — Аutonomous Non-Profit Organization “Institute of marine instrumentation and robotics”, JSC “Yevpatoria aircraft repair plant”, etc.
  • Iranian militaries and the management of companies engaged in the production of unmanned aerial vehicles (UAVs) — Commander of the Islamic Revolutionary Guard Corps Aerospace Force Iran, Aghajani Saeed Ara Jani; Head of the Islamic Revolutionary Guard Corps Aerospace Force, Mehrabi Abdollah; Managing Director of Oje Parvaz Mado Nafar Company (Mado), Abutalebi Yousef, etc.
  • Iranian companies involved in the production and transportation of the UAVs and other military goods — Paravar Pars Company, Design and Manufacturing of Aircraft Engines (DAMA), Baharestan Kish Company, Oje Parvaz Mado Nafar Company (Mado), Safiran Airport Services, Shahed Aviation Industries Company, Iran Aircraft Industries Company, etc.
  • Syria’s high officials — Bashar Hafez al-Asad, Husein Arnus and Feisal аl-Mikdad
  • UAE companies facilitating the transfer of the Iranian UAVs to Russia — I Jet Global DMCC and Success Aviation Services FZC

The full lists of individuals and legal entities subject to sanctions are set forth in the annexes to the Decision.

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. 163/2023 dated 18 March 2023 “On the Decision of the National Security and Defense Council dated 18 March 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 21 March 2023 (the “Decision“).


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.