Digest: Ukrainian Sanctions, vol.3 – January-March 2025
Contents
- Sanctions imposed during January-March 2025 > read
- Ukrainian State Registry of Sanctions and War&Sanctions Portal > read
- Forfeiture of assets of sanctioned persons in favour of Ukraine > read
- Challenging sanctions in court > read
- Legislative changes > read
Sanctions imposed during January-March 2025
During January – March 2025, the President of Ukraine has issued 5 decrees on the application (amendment) of personal sanctions against 68 legal entities and 210 individuals.
| Issued: | Sanctioned: | |
|---|---|---|
| 5 decrees | 68
legal entities 210
individuals |
In particular, such sanctions were imposed on:
- individuals and legal entities from the Russian Federation who are associated with the economy of the Russian Federation (Decree No.24/2025 of 13 January 2025);
- propagandists working for Russia. The sanctioned individuals include Nestor Shufrych, Yevhen Muraiev, Petro Symonenko, Kostiantyn Hryhoryshyn, Ruzhena Rubliova (Decree No.38/2025 of 19 January 2025);
- individuals from the Russian Federation and Iran who facilitated the export of Ukrainian national property from the temporarily occupied territories, as well as against the Russian shadow fleet (Decree No.67/2025 of 5 February 2025);
- individuals and legal entities from the Russian Federation, including the Federal State Budgetary Institution of Culture “State Historical and Archaeological Museum-Reserve “Tauric Chersonese ” (Decree No.68/2025 of 5 February 2025);
- Ukrainian individuals, including Ihor Kolomoiskyi, Hennadii Boholiubov, Kostiantyn Zhevago, Petro Poroshenko and Viktor Medvedchuk (Decree No.81/2025 of 12 February 2025).
Ukrainian State Registry of Sanctions and War&Sanctions Portal
As of 31 March 2025, the State Registry of Sanctions contained information on
30 741
Sanctions actions (imposing, amending, cancelling sanctions) 10 714
Sanctioned individuals 7 480 Sanctioned legal entities |
The Portal (War&Sanctions Portal) has been regularly updated with new sections. In particular, at the beginning of 2025, a new section “UAV manufacturers” was added to the portal with data on Russian arms and military equipment manufacturers. The first on the list is UAV manufacturers.
The section contains identification data of enterprises, information on UAV models in production, a general description of the companies' activities, and a list of related companies. The view is available both by enterprises and drone models. For some models, there is also information on foreign components and assemblies found in UAVs used against Ukraine.
Forfeiture of assets of sanctioned persons in favour of Ukraine
During January – March 2025, the High Anti-Corruption Court has registered 5 new statements of claim for forfeiture of assets in favour of Ukraine. Also, during this period, the High Anti-Corruption Court fully or partially granted 6 claims which have been submitted in 2024 and 2025 against the following individuals and legal entities: Public Joint Stock Company Tatneft named after V.D. Shashin, the Federal Autonomous Institution “Russian Maritime Register of Shipping”, Vyshynskyi Kyrylo Valeriiovych, Zanevskyi Viacheslav Yevhenovych, Kuzmenko Oleksandr Viktorovych, Serhiienko Volodymyr Volodymyrovych.
As a result, during January – March 2025, the High Anti-Corruption Court has forfeited in favour of the state:
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| 11 real estate objects with a total area 3,322.6 m2 |
14 land plots with a total area 21,648 m2 |
2 parking spaces with a total area 25.7 m2 |
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| 11 vehicles |
shares in 10 companies |
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and other types of assets such as funds, property rights, etc.
Challenging sanctions in court
During January – March 2025, the Supreme Court registered and listed for the hearing 23 statements of claim challenging the decrees of the President of Ukraine on the application of personal sanctions.
Furthermore, the Supreme Court has considered 4 cases challenging the sanctions and denied 3 statements of claim.
Important!
On 10 February 2025, the Supreme Court of Ukraine cancelled personal sanctions for the first time in case No. 990/176/23. According to the Supreme Court's decision, the claimant, a citizen of France, proved that as of the date of the application of the sanctions, he had not held the position of a member of the board of directors or any other position in Setelem Bank LLC, which is a part of the group of the PJSC Sberbank of Russia, for several years. As a result, the court established that there were no grounds for imposing personal sanctions on the claimant under the Law of Ukraine “On Sanctions”. As of today, this decision has been appealed to the Grand Chamber of the Supreme Court.
Legislative changes
During January – March 2025, a number of important bills have been registered that may have a significant impact on Ukrainian sanctions legislation. Among them, special attention should be paid to the following:
- On 14 January 2025, the President of Ukraine submitted to the Parliament Bill No. 12406 to establish criminal liability for violation and circumvention of sanctions imposed under the Law of Ukraine “On Sanctions”. In particular, it is proposed to supplement the section of the Criminal Code of Ukraine on crimes against the foundations of national security of Ukraine with a new Article 114-3, which establishes liability for violation of a restrictive measure (sanction), as well as intentional circumvention of sanctions.
The bill also provides for amendments to the Law of Ukraine “On Sanctions”, in particular, its supplementation with Articles 5-5 and 5-6, which clarify which actions should be considered as circumvention of sanctions. For a detailed overview of the bill, please [follow the link] https://www.integrites.com/uk/publications/criminal-liability-for-violation-of-ukrainian-sanctions/). - On 17 February 2025, the Verkhovna Rada registered Bill No. 13020, which provides for amendments to the Law of Ukraine “On Sanctions” in the part of sanctions applied to ships and aircraft involved in the Russian shadow transportation of oil and oil products, weapons and military.
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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