Digest: Ukrainian Sanctions, vol. 5 (July – September 2025)
Contents
- Sanctions imposed during July – September 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 July – September 2025
During July – September 2025, the President of Ukraine issued 21 decrees on the imposition of (amendments to) personal sanctions against 884 legal entities and 749 individuals.
| Issued: | Sanctioned: | |
|---|---|---|
| 21 decrees | 884
legal entities 749
individuals |
In particular, sanctions were imposed on:
- individuals and legal entities associated with Russia's cryptocurrency schemes (Decree No. 465/2025 of 6 July 2025);
- supplier companies whose parts were found in Russian strike drones, in particular against: Central Asia Silk Road International Trade (Tianjin) Co., Ltd, Suzhou Ecod Precision Manufacturing Co., Ltd, Shenzhen Royo Technology Co., Ltd, Shenzhen Jinduobang Technology Co., Ltd, Ningbo BLIN Machinery Co., Ltd. (Decree No. 466/2025 of 8 July 2025);
- individuals and legal entities in accordance with proposals of the Cabinet of Ministers of Ukraine regarding synchronisation of Ukrainian sanctions against Russia with the 15th, 16th, 17th and 18th packages of restrictive measures (sanctions) of the EU (Decree No. 471/2025 of 8 July 2025, Decree No. 472/2025 of 8 July 2025, Decree No. 473/2025 of 8 July 2025, Decree No. 554/2025 of 27 July 2025);
- individuals who participated in information campaigns aimed at undermining Ukraine's defence capabilities, promoting anti-Ukrainian narratives and legitimising the armed aggression of the Russian Federation (Decree No. 502/2025 of 20 July 2025);
- individuals and legal entities associated with the extraction of rare earth and rare metals used for the production of electronics, guidance systems, engines and drones (Decree No. 555/2025 of 27 July 2025);
- individuals and legal entities, including Argo Tanker Group, LLC; Gazpromneft Shipping, LLC; SKF ECO, LLC; SKF Pryrozlomne, LLC; and SKF TM, LLC (Decree No. 578/2025 of 3 August 2025);
- individuals and legal entities associated with the export of grain stolen from occupied territories, illegal extraction and enrichment of minerals, as well as on captains of the "grain" shadow fleet (Decree No. 579/2025 of 3 August 2025);
- individuals who are directors of Russian museums that appropriate Ukrainian cultural valuables, conduct exhibitions glorifying the aggression of the Russian Federation (Decree No. 580/2025 of 3 August 2025);
- individuals and legal entities involved in the energy sector and military-industrial complex of Russia (Decree No. 594/2025 of 8 August 2025);
- individuals and legal entities involved in attempts to integrate the Zaporizhzhia nuclear power plant into Russia's energy system, the seizure of the Chornobyl nuclear power plant, production and maintenance of dual-use nuclear equipment, as well as the export of enriched uranium through subsidiaries in Switzerland, Cyprus, the Netherlands and Finland (Decree No. 595/2025 of 8 August 2025);
- individuals and legal entities involved in the Russian military-industrial complex aimed at producing drones using artificial intelligence (Decree No. 599/2025 of 16 August 2025);
- individuals and legal entities engaged in conducting business in the temporarily occupied territory of Ukraine and propaganda activities (Decree No. 612/2025 of 23 August 2025);
- individuals and legal entities involved in the industrial and energy sectors of the Russian Federation, the Russian military-industrial complex, propaganda of Russian narratives abroad, information operations against Ukraine, as well as representatives of Russian state authorities and Belarusian security structures (Decree No. 613/2025 of 23 August 2025);
- individuals and legal entities that assist the military-industrial complex, shadow fleet and energy sector of Russia (Decree No. 675/2025 of 10 September 2025);
- individuals and legal entities involved in the supply and implementation of IT and communication solutions, as well as engaged in the processes of supply, development, production of electronic warfare for the Russian military-industrial complex (Decree No. 676/2025 of 10 September 2025);
- individuals who disseminated anti-Ukrainian publications and justified Russia's armed aggression against Ukraine (Decree No. 694/2025 of 20 September 2025);
- individuals, including officials of occupying authorities in the territory of temporarily occupied Crimea, representatives of Russia's judiciary involved in human rights violations in Crimea, organisations engaged in assisting the Russian army, etc. (Decree No. 695/2025 of 20 September 2025);
- individuals who are public and political figures of Moldova promoting pro-Russian narratives and justifying Russia's aggression (Decree No. 696/2025 of 20 September 2025).
Ukrainian State Registry of Sanctions
As of 30 September 2025, the State Registry of Sanctions contained information on
33 819
Sanctions actions (imposing, amending, cancelling sanctions) 12 355
Sanctioned individuals 8 888 Sanctioned legal entities |
New Research by the Yermak-McFaul Sanctions Group
In September 2025, the International Working Group on Russian Sanctions released its new document containing a comprehensive plan to strengthen sanctions pressure on Russia.
⛽️ Oil sanctions
The document calls for a significant expansion of sanctions against Russia’s “shadow fleet” (over 400 tankers, with an additional 300+ vessels to be sanctioned by the U.S.), a reduction of the oil price cap to 15% below market value, and the introduction of escrow accounts for payments for Russian energy exports, following the Iranian model.
It also recommends imposing additional fees on tankers carrying Russian oil, applying secondary sanctions to Russia’s key oil buyers (India, China, and Turkey), introducing port embargoes on selected Russian ports, and accelerating the EU’s full abandonment of Russian oil, LNG, and gas imports by 2026.
💵 Financial sanctions
It is proposed to sanction all 308 Russian banks, prohibit any interaction of Western financial institutions with them (including Russian branches of Unicredit, Raiffeisen and OTP) unless specifically licensed. It is also recommended banning the use of cryptocurrencies and stablecoins to circumvent sanctions and introduce personal sanctions against senior officials of the Russian Ministry of Finance, the Central Bank, and state-owned banks.
🛰️ Technology restrictions
Russia continues to receive critical military technologies through China and intermediaries in Central Asia, Turkey and the UAE. It is proposed to establish a system of international verification of end users for high-tech equipment, add composite materials, CNC machines, metrology systems and software to control lists, as well as limit trade in sensitive goods with third countries at the level of 2021, with the introduction of automatic sanctions when quotas are exceeded.
⚖️ Confiscation of frozen assets
Experts propose that the EU independently confiscate over $300 billion of frozen Russian assets (predominantly in Euroclear) and transfer them to Ukraine. This will provide up to $100 billion annually to support the state and defence and will be a strategic investment in European security. Using Russian funds to finance the Ukrainian army and reconstruction is considered not only moral but also strategically justified.
Document No. 23
Action Plan 4.0. "New Sanctions to Pressure Russia to Agree to a Ceasefire in Ukraine", September 2025, (PDF)
Forfeiture of assets of sanctioned persons in favour of Ukraine
During July – September 2025, the High Anti-Corruption Court (HACC) registered 5 statements of claim for forfeiture of assets in favour of Ukraine (cases No. 991/7476/25, No. 991/8082/25, No. 991/9917/25, No. 991/10013/25 and No. 991/10090/25).
Also, during this period, HACC fully or partially granted 2 statements of claim against the following individuals:
- Oliinyk Volodymyr Mykolaiovych (former mayor of Cherkasy (from 1994 to 2002), Member of the Parliament of Ukraine, one of the founders of the anti-Ukrainian organisation "The Ukraine Salvation Committee", which actively spreads Russian propaganda and supports Russia's aggression against Ukraine), case No. 991/7476/25;
- Kalashnyk Serhii Viktorovych (a sitting member of the Federation Council of the Russian Federation representing the executive authority of the Kostroma Region), case No. 991/8082/25.
As a result, during July – September 2025 (taking into account the decision of the Appellate Chamber of the HACC dated 2 October 2025 in case No. 991/7476/25), the HACC forfeited in favour of the state:
🏡
Real estate objects with a total area of 663 sq.m
🪧
3 land plots with a total area of 0.2579 ha
🛥️
Self-propelled, motorised pleasure vessel
📋
Corporate share in E.S.P. TECHNOLOGIES, LLC
🗂️
Claims against Motordetal-Konotop, LLC, totalling more than UAH 95 million
Challenging sanctions in court
During July – September 2025, the Supreme Court registered 23 statements of claim seeking to challenge Decrees of the President of Ukraine imposing (amending) personal sanctions issued after the full-scale invasion.
During this period, the Supreme Court made decisions in 4 cases challenging sanctions, in which the claims were denied, namely:
- Сase No. 990/264/23 – claim filed by Lukianenko Volodymyr Matviiovych (former Chairman of the Board of OJSC "Sumy Machine-Building Science-and-Production Association named after M.V. Frunze");
- Сase No. 990/70/23 – claim filed by Zinharevych Anton Borysovych (former owner of Reading Football Club, son of Russian multimillionaire Zinharevych Borys Hennadiiovych)
- Сase No. 990/261/23 – claim filed by FEDCORP, JSC (Luxembourg);
- Сase No. 990/66/23 – claim filed by Rappoport Andrii Natanovych (co-founder and first head of Alfa-Bank).
Legislative changes
Between July and September 2025, a number of important laws, decrees and draft bills relating to Ukrainian sanctions legislation were adopted and registered. Among them, special attention should be paid to the following:
📕
On 30 July 2025, the President signed the Law of Ukraine "On Amendments to the Law of Ukraine "On Sanctions" regarding the application of sanctions to vessels and aircraft".
The Law provides for amendments to the Law of Ukraine "On Sanctions" regarding the possibility of applying sanctions not only to individuals and legal entities, but also to vessels and aircraft which activities create real and potential threats to national interests, national security, territorial integrity, sovereignty and independence of Ukraine.
📕
Subsequently, on 16 August 2025, corresponding amendments were made to the Regulation on the State Registry of Sanctions (Decree of the President of Ukraine No. 600/2025 of 16 August 2025, which enacted the decision of the NSDC "On Amendments to the Regulation on the State Registry of Sanctions" of 16 August 2025).
Now the State Registry of Sanctions also contains information about:
⚓️ Vessels
Name of vessel, International Maritime Organisation identification number (IMO number) – for seagoing vessels, unique European identification number (ENI number) – for inland vessels, name of shipowner, national affiliation of vessel (state under whose flag the vessel sails), vessel call sign, maritime mobile service identity (vessel MMSI);🛩️ Aircraft
Type/model of aircraft, year of manufacture, registration certificate number, state mark, factory (serial) number, name of owner, name of aircraft operator.
📕
On 3 September 2025, Draft Bill No. 14002 on amendments to the Law of Ukraine "On Sanctions" was registered.
The draft seeks to supplement Article 3 of the Law by establishing that the decision of a competent authority of a foreign state imposing restrictive measures (sanctions) in connection with armed aggression against Ukraine shall also serve as a legal ground for the application of Ukrainian sanctions.
The draft law also proposes to authorise the Ministry of Foreign Affairs of Ukraine to submit to the NSDC proposals concerning the imposition, lifting, or amendment of the following types of sanctions: restriction of trade operations; restriction, partial or complete suspension of transit of resources, flights and transportation through the territory of Ukraine; prevention of capital withdrawal beyond Ukraine's borders; suspension of fulfilment of economic and financial obligations.
In addition, the bill would expand the grounds for lifting sanctions – allowing for their cancellation based on: UN resolutions; decisions of the EU Council decisions of the EU Council aimed at protecting Ukraine’s national interests, as well as decisions of competent authorities of foreign states adopted in connection with armed aggression against Ukraine, provided that the sanctions were originally imposed on the grounds set out in paragraphs 2-5 of part 1 of Article 3 of the Law "On Sanctions".
📕
On 8 July 2025, Draft Resolution of the Verkhovna Rada of Ukraine No. 13460 was registered. The document proposes that the Parliament approve recommendations for the imposition of sanctions against representatives of sports organisations of the Russian Federation. It recommends that the NSDC adopt a corresponding decision on the application of these sanctions and ensure notification of competent authorities of the EU, U.S., Canada, Australia, Japan and other states for their consideration of the introduction of similar restrictive measures.
Access Sanctions Digest vol.4 (April – June 2025)
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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