UKRAINE Law and Practice Contributed by: Denys Bugay, Volodymyr Vashchenko and Denys Shkarovsky, VB Partners
7.3 Circumvention 7.3.1 Prohibiting Provisions The provisions prohibiting the circumvention of sanc - tion restrictions are not provided for by law. 7.3.2 Criminal Penalties In Ukraine, legal liability, including of a criminal nature, for the circumvention of sanctions, is not provided for. However, Ukraine is taking active steps towards criminalising sanctions violation and/or circumvention.
participating in the privatisation of state and commu - nal property. In addition, the entities controlled by sanctioned per - sons may be deprived of the opportunity to receive banking services (banks may refuse to conduct bank - ing operations (transactions) or even block accounts on the basis of internal acts and compliance policies), and registration services (make changes to informa - tion in the Register of Legal Entities).
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