Digest: Ukrainian Sanctions, vol. 4 (April – June 2025)
Contents
- Sanctions imposed during April – June 2025 > read
- Ukrainian State Registry of Sanctions > read
- New Research of Yermak-McFaul Sanctions Group > read
- Forfeiture of assets of sanctioned persons in favour of Ukraine > read
- Challenging sanctions in court > read
- Legislative changes > read
Sanctions imposed during April – June 2025
During April – June 2025, the President of Ukraine has issued 18 decrees on the application (amendment) of personal sanctions against 536 legal entities and 907 individuals.
| Issued: | Sanctioned: | |
|---|---|---|
| 18 decrees | 536
legal entities 907
individuals |
In particular, such sanctions were imposed on:
- propagandists who justify Russia’s war against Ukraine
(Decree No. 229/2025 of 11 April 2025); - individuals and legal entities involved in spreading disinformation, cooperating with occupation administrations, or supporting Russian aggression
(Decree No. 230/2025 of 11 April 2025); - officials from the presidency of Viktor Yanukovych, including Serhiy Arbuzov, Andriy Klyuyev, Viktor Polishchuk, and Alyona Shevtsova
(Decree No. 231/2025 of 12 April 2025); - Russian cultural and sports figures, such as Nikolay Tsiskaridze, Igor Sukachyov, Aleksandr Rozenbaum, Nikolay Rastorguyev, and Sergey Polunin
(Decree No. 246/2025 of 18 April 2025); - individuals and legal entities supplying military goods to Russia, including gunpowder and artillery, among them three Chinese companies: Beijing Aviation And Aerospace Xianghui Technology, Rui Jin Machinery, and Zhongfu Shenying Carbon Fiber Xining
(Decree No. 247/2025 of 18 April 2025); - political analysts, bloggers, propagandists, and former officials, including former adviser to the Head of the Office of the President of Ukraine Oleksiy Arestovych and blogger Myroslav Oleshko
(Decree No. 267/2025 of 1 May 2025); - individuals and entities servicing Russia’s military production in the energy and engineering sectors
(Decree No. 268/2025 of 1 May 2025); - dual citizens and charitable organisations supporting the war against Ukraine
(Decree No. 269/2025 of 1 May 2025); - individuals and legal entities, including Oleksandr Shenshyn, Denys Pytiev, and Oleksiy Minochkin
(Decree No. 301/2025 of 9 May 2025); - individuals and legal entities linked to Pin-Up, including LLC “Ukr Game Technology”, LLC “Tranitadevelopment”, LLC “Turbo.ua”, and LLC “Viktoria-Soft”
(Decree No. 344/2025 of 25 May 2025); - Ukrainian and Russian officials, including Oleksandr Bohuslaiev, Akhmed Dudayev, Serhiy Lalakin, and Rostyslav Shaposhnikov
(Decree No. 345/2025 of 25 May 2025); - individuals and legal entities involved in the policy of russification of Ukrainian children
(Decree No. 395/2025 of 10 June 2025); - individuals and legal entities engaged in the development and production of unmanned aerial vehicles, FPV systems, as well as suppliers and importers of their components
(Decree No. 415/2025 of 20 June 2025); - individuals and legal entities cooperating with the occupying authorities in the temporarily occupied territories, including Crimea
(Decree No. 417/2025 of 22 June 2025); - individuals and legal entities supplying machine tools and other equipment to Russia’s military-industrial enterprises
(Decree No. 423/2025 dated 27 June 2025); - individuals and legal entities subject to restrictive measures pursuant to decisions and implementing regulations of the Council of the European Union
(Decrees No. 445/2025 and No. 442/2025 of 29 June 2025); - individuals and legal entities subject to restrictive measures under EU Council decisions regarding the Islamic Republic of Iran
(Decree No. 443/2025 of 29 June 2025).
Ukrainian State Registry of Sanctions
As of 30 June 2025, the State Registry of Sanctions contained information on
31,595
Sanctions actions (imposing, amending, cancelling sanctions) 11,207
Sanctioned individuals 7,819 Sanctioned legal entities |
New Research by the Yermak-McFaul Sanctions Group
Between April and June 2025, the International Working Group on Russian Sanctions released a new working group paper outlining a comprehensive strategy to strengthen economic pressure on Russia with the aim of accelerating the end of the war in Ukraine. The document offers a set of practical measures for the sanction coalition states, including:
- Strengthening energy sanctions: lowering the oil price cap; introducing freight charges for oil loading in Russia; banning imports of liquefied natural gas from “Yamal”; imposing tariffs on all imports of Russian oil and gas into the EU.
- Pressure on the military-industrial complex: sanctions against Russian defense enterprises, their executives and employees; blocking imports of dual-use components via third countries; restoring coordinated export control (a CoCom-style mechanism).
- Asset confiscation: recommendation for the EU to confiscate over $300 billion in frozen assets of the Russian Central Bank to finance Ukraine’s defense and reconstruction.
- Financial restrictions: expanding bans on correspondent banking relationships, cryptocurrency transactions, investments in Russia’s state sector, and intermediary payment schemes; tightening compliance requirements for banks.
- Technological isolation: secondary sanctions on companies from intermediary countries; a complete ban on cloud services, AI tools, and software for Russian entities; supply chain and end-use controls.
- Export quotas: introducing quotas on exports of high-tech goods to countries that facilitate re-exports to Russia (such as Turkey, the UAE, Kazakhstan, and Kyrgyzstan).
The document also emphasises the need for the EU to take a leading role in the sanctions coalition in light of the growing unpredictability of U.S. policy.
Document No. 22 Action Plan 4.0. Strengthening Sanctions Against the Russian Federation, May 2025 (PDF)
Forfeiture of assets of sanctioned persons in favour of Ukraine
In the second quarter of 2025 , the High Anti-Corruption Court (HACC) registered two statements of claim seeking the forfeiture of assets in favour of Ukraine (cases No. 991/5298/25 and No. 991/3297/25). During this period, the HACC also:
granted four claims against:
- Kyrylo Vyshynskyi (former Ukrainian journalist who obtained Russian citizenship and became a mouthpiece of kremlin propaganda), case No. 991/5298/25;
- Tetiana Bratchenko (director of the Kherson Regional Museum of Local Lore), case No. 991/3297/25;
- OJSC “Belaruskali”, case No. 991/2148/25;
- International Company PJSC “United Company RUSAL” and Oleg Deripaska (one of Russia’s wealthiest oligarchs, billionaire close to the Russian president), case No. 991/1932/25;
denied one claim concerning Oleksii Popov (businessman and owner of a gas station network in Melitopol), case No. 991/13759/24.
During the same period, the Appeals Chamber of HACC reviewed four decisions concerning asset forfeiture sanctions in the following cases:
- No. 991/10700/23 concerning JSC “HMS Group”, Volodymyr Lukyanenko Sr., his son Volodymyr Lukyanenko Jr., and Russian citizen Herman Tsoi;
- No. 991/13759/24 concerning Oleksii Popov;
- No. 991/699/25 concerning Volodymyr Serhiyenko (a pro-Russian political analyst);
- No. 991/2148/25 concerning OJSC “Belaruskali”.
As a result, during April – June 2025, the High Anti-Corruption Court has forfeited in favour of the state:
 |
 |
|||||
| 5 real estate objects | 1 land plot | |||||
 |
 |
|||||
| 25 vehicles |
shares in 24 companies |
|||||
and other types of assets (including bauxite, metallurgical and processed alumina totaling 427,758.19 tonnes valued at UAH 2,110,176,184.09, monetary funds, property rights, 1,545 railcars, and more).
Challenging sanctions in court
From April to June 2025, the Supreme Court of Ukraine registered 12 statements of claim challenging Decrees of the President of Ukraine imposing personal sanctions issued (amended) after the full-scale invasion.
During this period, the Supreme Court denied 3 statements of claim, filed by:
- Oleksii Maslennikov (former Metropolitan of Romny and Buryn), case No. 990/109/23;
- Tymur Rodionov (former beneficiary of the Reikartz Hotel Group chain), case No. 990/224/23;
- Yuliia Voynikova (shareholder of the business from temporarily occupied Berdiansk, which continued its operations in Russia following the occupation), case No. 990/37/24.
Legislative changes
Between April and June 2025, a number of important draft laws and presidential decrees were initiated that can significantly impact Ukrainian sanctions legislation. Notably:
- On 3 June 2025, the Verkhovna Rada passed in the first reading Presidential Draft Law No. 12406 “On Amendments to the Criminal Code of Ukraine, the Criminal Procedure Code of Ukraine, and the Law of Ukraine “On Sanctions” regarding the establishment of liability for violations of special economic and other restrictive measures (sanctions).
This draft law also introduces amendments to the Law of Ukraine “On Sanctions,” in particular by adding Articles 5-5 and 5-6, which clarify what actions should be considered circumvention of sanctions. A detailed overview of the draft law is available via link. - On 23 May 2025, Draft Law No. 13311 was registered in the Verkhovna Rada, proposing to establish joint liability for members of the National Security and Defense Council of Ukraine (NSDC) regarding the legality of their decisions on the imposition of sanctions.
The draft law also proposes to add Article 5-5 to the Law of Ukraine “On Sanctions” to regulate liability for the unlawful application of sanctions, including through compensation for damages. - On 27 June 2025, the President signed Decree No. 422/2025, enacting the NSDC decision of 27 June 2025 “On the synchronisation of Ukraine’s sanctions pressure with that of the European Union, G7 countries, and other partners against the Russian Federation and affiliated entities.” The decision aims to ensure the implementation in Ukraine of restrictive measures adopted by international partners.
It obliges the Cabinet of Ministers of Ukraine (CMU), the Security Service of Ukraine (SBU), and the National Bank of Ukraine to fully implement in Ukraine the sanctions adopted by international partners. These sanctions must be synchronised through submission to the NSDC no later than the 15th day after the respective decision of the partner state or alliance enters into force.
Additionally, the decision tasks the CMU, SBU, Foreign Intelligence Service, and the Prosecutor General’s Office with ensuring synchronisation with the EU, US, and other countries of sanctions imposed by Ukraine in response to the Russian Federation’s armed aggression.
Access Sanctions Digest vol.3 (January – March 2025)
Access Sanctions Digest vol.2 (October – December 2024)
Access Sanctions Digest vol.1 (January – September 2024)
The digest prepared by Business Protection, Compliance and Anti-Corruption team
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