Sanctions 2025

UKRAINE Law and Practice Contributed by: Denys Bugay, Volodymyr Vashchenko and Denys Shkarovsky, VB Partners

1. Trends and Overview 1.1 Sanctions Market

1.3 Key Industries In Ukraine, the institution of sanctions was introduced in August 2014 in response to Russia’s annexation of Crimea and armed conflict in the East. The purpose of sanctions imposition in Ukraine is to protect the national interests, national security, sov - ereignty and territorial integrity of Ukraine; countering terrorist activity; prevention of violations, restoration of violated rights, freedoms and legitimate interests of Ukrainian citizens, society and the state. Taking the above into account, sanctions were mainly imposed on Russian individuals and legal entities or those affiliated with them. At the same time, sanctions were imposed on several Ukrainian individuals and legal entities (not related to the Russian Federation), who may pose a threat to the national security, sovereignty and territorial integrity of Ukraine. From the analysis of the entities on which sanctions have been imposed, it follows that the industries, logistics, communications, energy, science and edu - cation, as well as the field of public and military groups and government structures were most affected. In 2025, sanctions started to be used to prosecute direct political opponents. For example, in February 2025, the President of Ukraine, Volodymyr Zelenskyy,imposed sanctions on a direct political opponent, the fifth President of Ukraine, Petro Poroshenko. 1.4 Overview 1.4.1 Types of Sanctions The Law of Ukraine “On Sanctions” provides for the possibility of imposing both personal and sectoral sanctions. Personal sanctions are imposed on specific individuals, while sectoral sanctions are imposed on a foreign state or undefined group of persons carrying out a certain type of activity. Types of Sanctions Until 22 May 2022 • The initial version of the above Law provided 24 types of clear sanctions (blocking of assets, restric -

In Ukraine, the sanctions sector has been rapidly developing since 2014 because of Russia’s annexa - tion of Crimea and armed conflict in the East. In 2024, sanctions were imposed on more than one thousand legal entities and individuals. Although the number of sanctions imposed in 2024 has decreased compared to 2023 (when more than 7,000 individuals and legal entities were designated), sanctions remain a tool used against the aggressor state and those who support the Russian Federation. The number of lawsuits to impose a sanction intro - duced in 2022 – confiscation of the assets of the Rus - sian Federation’s accomplices into the state income filed by the Ministry of Justice of Ukraine – remains almost at the same level. In 2023, the Ministry of Justice of Ukraine filed 31 lawsuits. In 2024, the number of lawsuits was 28. In Ukraine, the COVID-19 pandemic has not affected the sanctions sector at all. The imposition of sanctions is caused by the full-scale invasion of the Russian Federation in Ukraine. 1.2 Key Trends Within the last 12 months in the sanctions sector, the authors have observed: • active steps to finally criminalise sanctions violation and/or circumvention; and • actions aimed at preventing co-operation with those who in any way contribute to the war against Ukraine. In June 2024, the Main Intelligence Directorate of the Ministry of Defense of Ukraine launched the “Main Portal on Sponsors and Accomplices of Aggression”. Since that time, the portal has been significantly developed.

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