Effective as of 25 November 2023, Ukraine introduced two new sets of personal sanctions against 147 individuals and 303 legal entities (“Sanctions”), in particular:[1]

(a) the following Russian companies:

  • Military-industrial enterprises: JSC “Duks”, JSC “Design and Production Enterprise ‘Iris'”, JSC “Okenit”, JSC “Moscow Design Industrial Complex ‘Universal'”, etc.
  • Machine building enterprises: JSC “Gavrilov-Yamsky Machine Building Plant ‘Agat'”, JSC “Machine-Building Plant ‘Armalit'”, etc.
  • Energy companies: JSC “United Energy Company”, JSC “Vologda Regional Energy Company”, JSC “Moscow Regional Power Grid Company”, etc.
  • Metallurgical plant JSC “Oskolsky Electric Steel Works named after Aleksey Alekseevich Ugarov”
  • Radio electronics enterprise LLC “Moscow Plant ‘Fizpribor'”
  • Companies providing communication and telecommunication services: LLC “AF Telecom Holding”, LLC “USM Telecom”, LLC “Moskomsvyaz”, etc.
  • Real estate and property management companies: LLC “GKR-Nedvizhimost”, LLC “Novogorsk Nedvizhimost”, LLC “Pankastor Property Management”, etc.
  • Transport companies: Volgograd Region State Unitary Enterprise “Volgogradavtotrans”, LLC “Dontranslogistik,” etc.
  • Investment and financial companies: JSC “Investkontrast”, JSC “Guta-Insurance”, LLC “Moscow Stock Center”, etc.
  • Food and consumer products (including agricultural, confectionery): LLC “Eastern Grain Gate”, LLC “Bichevninsky Grain Elevator”, PJSC “Moscow Confectionery Factory ‘Krasny Oktyabr'”, OJSC “Babaevsky Confectionery Concern”, etc., and
  • Cosmetic companies: JSC “Faberlic”, LLC “Sengara”, LLC “Faberlic Fashion Factory”, etc.

(b) the following foreign companies:

  • related to or assisting Russian businesses: Vassiliades & Co (UK) Limited (United Kingdom), Waldau Investments Limited (Cyprus), The Sister Trust (Switzerland), Metalloinvest Trading AG (Switzerland), Group C Universal Limited (British Virgin Islands), S.R.L. Thermex Mld (Moldova), etc., and
  • having close ties with Yevgeny Prigozhin (former leader (reported dead) of Private Military Company Wagner): Dubai-based distributor of industrial goods Industrial Resources General Trading (United Arab Emirates) and mining company Midas Ressources SARLU (Central African Republic).

(c) citizens of the Russian Federation, Ukraine, Cyprus, Belarus, Germany, Uzbekistan, Austria and the United Kingdom considered to be involved in supporting Russian aggression against Ukraine.

The Decisions impose an extensive set of 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 securities transactions; suspension of financial transactions; and prohibition on conclusion of contracts and execution of transactions. The particular set of sanctions applicable to each person is set forth in the annexes to the Decisions.

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. 772/2023 dated 23 November 2023 “On the Decision of the National Security and Defense Council dated 23 November 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 25 November 2023; Presidential Decree No. 773/2023 dated 23 November 2023 “On the Decision of the National Security and Defense Council dated 23 November 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 25 November 2023 (“Decisions“).


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.