On 14 May 2018, the President of Ukraine enacted the decision of the National Security and Defence Council of Ukraine of 2 May 2018 “On the Application and Repealing of Personal Special Economic and Other Restrictive Measures (Sanctions)” (“NSDC Decision”). The NSDC Decision does the following:

• updates the previous lists of sanctions against individuals and companies, including those individuals and companies the list of which was specified in our “Legal alert” of 2 June 2017
• expands the list of sanctioned persons

Generally, the sanctions limit economic activities in Ukraine and prevent certain individuals from entering the country.

The sanctions specified in the NSDC Decision entered into force on 19 May 2018 and will expire in 1 year or 3 years (if not extended), or will have an unlimited duration, depending on the category of the sanctioned persons.

Who is subjected to sanctions?

The sanctions listed in the NSDC Decision have effect against 1,748 individuals and 756 companies.

Companies

These are mostly Russian companies and their subsidiaries in Ukraine, which may broadly be divided into several categories:

1. banks and non-banking institutions, stock exchanges
2. airlines and aviation enterprises
3. lottery companies, charity funds, and other organisations
4. IT-companies, including antivirus companies, software developers, social media, and destination sites, as well as companies, which develop geoinformation systems
5. mass media
6. Crimean seaports, transporting and shipping companies
7. manufacturing and technology companies, plants, trading and transit companies, supplying companies, oil and gas companies
8. companies within the territory of Crimea, including state enterprises, which were re-registered according to Russian law, educational and scientific institutions

Individuals

The individuals subjected to the sanctions fall under the following categories:

1. Russian artists and scientists, journalists of Russian or separatist press
2. Russian military, judges, attorneys, members of parliament, public persons, and other public officials
3. members of radical and separatist parties and organisations
4. founders of Russian banks
5. shareholders, supervisory directors, and directors of Russian joint stock companies
6. directors of Russian research institutions, corporations, and enterprises
7. founders of Russian IT-companies
8. people engaged in separatist and terrorist activities in the East of Ukraine and in Crimea

How do sanctions affect your business?

Due to the restrictions imposed on the activities of the sanctioned persons, any person dealing with any of them should carefully assess the implications of any transactions with them.

For your convenience, we have prepared a summary table that includes the companies against whom the sanctions had been introduced previously (green in the table) and the companies against whom the sanctions have been recently introduced (blue in the table). It will enable you to identify the sanctioned companies and the scope of the sanctions imposed on each of them. You may access the table by clicking here.

If you have any questions on the regime of the sactions or on the risks, which may arise as a result of co-operating with the sanctioned companies, AVELLUM team will be ready to provide a qualified legal advice on such matter.