On 19 February 2021, Ukraine imposed[1] personal sanctions against a number of companies and individuals doing business in the Crimea and on the occupied territories of Donetsk and Luhansk regions (“Temporary Occupied Territories“) and suspected of terrorism financing, as well as on certain Russian-owned businesses. The sanctions were imposed against:

  • Trading House Donskiye Ugli LLC, which allegedly sold coal produced on the Temporary Occupied Territories to the Russian Federation
  • Novoshakhtinsky Refinery Plant JSC for allegedly selling petroleum products to the Temporary Occupied Territories
  • IT companies Indusoft LLC and ISS Soft LLC
  • Sportmaster Operations Pte. Ltd, the owner of the major sportswear retail shop
  • pharmaceutical company Biotech LLC
  • medical equipment producers Haemogenics LLC and Medoborudovaniye LLC
  • Russian individuals — shareholders and managers of companies doing business on the Temporary Occupied Territories
  • pro-Russian politician Viktor Medvedchuk, notorious for his ties with the Russian president Vladimir Putin; Oksana Marchenko, the wife of Viktor Medvedchuk, and Natalia Lavrenyuk, the wife of the media tycoon Taras Kozak, who was sanctioned earlier this month
  • airway companies that operated illegal flights from Kyiv to Moscow

The Sanctions Decision imposes a broad set of restrictions on the sanctioned companies and individuals including:

  • assets freeze
  • restriction or full prohibition of trade transactions
  • suspension of performance of economic and financial obligations
  • prevention of the withdrawal of capital from Ukraine

The full list of sanctioned persons and applicable sanctions restrictions is set forth in the annexes to the Sanctions Decision. Any counterparty dealing with entities or individuals 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. 64/2021 dated 19 February 2021 “On the Decision of the National Security and Defense Council “On Imposition and Amendment of Personal Special Economic and other Restrictive Measures (Sanctions)” (“Sanctions Decision“), effective from 23 February 2021.


Hanna Shtepa is a Senior Associate of the Kyiv office of Baker McKenzie specializing in economic sanctions, export controls, international supplies of goods and services, public procurement regulations. She has significant experience on advising clients on supplies to Ukraine, participation in Ukrainian public procurement tenders, special regime of trade and business activities in the Crimea and uncontrolled territories in the East of Ukraine, Ukrainian sanctions restrictions against Russia. Hanna is experienced in drafting and negotiation of supply contracts, including procurement contracts for public needs, trade compliance policies and trade finance agreements. Hanna held a number of training and presentations for Ukrainian banks and corporate clients on compliance with Ukrainian sanctions and special trade regimes with the Crimea and uncontrolled territories in the East of Ukraine. She is one of the contributors to Baker McKenzie sanctions blog.