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 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.