Sanctions 2025

UKRAINE Trends and Developments Contributed by: Denys Shkarovsky, Volodymyr Vashchenko and Denys Bugay, VB Partners

(a) Punishment is imprisonment for six to ten years with disqualification from holding specific positions or engaging in specific activities for ten to 15 years, with or without confiscation of property. Conditions for exemption from criminal liability – the individual self-reports the crime prior to being charged with a notice of suspicion and assists in uncovering the crime or preventing the activities of an organised group or criminal organisation. Exemption does not apply to the organiser of the crime; the leader of the organised group or criminal organisation. The second key amendment to the Criminal Code of Ukraine is the possibility for a court to liquidate a legal entity if its authorised person commits a violation or circumvention of sanctions. The exception is that liquidation does not apply to banks. Key amendments to the Criminal Procedure Code The jurisdiction of a new crime falls within the compe - tence of the Security Service of Ukraine. The draft law enables the conduct of special pretrial investigations (in absentia) and special court proceed - ings for a new crime. Current status On 3 June 2025, the draft law passed its first reading. It is expected that no later than the end of summer 2025, a law criminalising sanctions violation and cir - cumvention will be adopted in Ukraine. Ukraine’s renewed effort to criminalise the violation and circumvention of sanctions demonstrates a clear political will to enhance accountability and bring its legal system closer to European standards. However, the draft law is far from perfect. It does not fully align with the requirements of the EU Directive. Some provisions remain vague or overly broad, poten - tially complicating enforcement and judicial interpre - tation.

Therefore, while the legislative initiative is a step in the right direction, it still requires significant refinement and expert input. Substantial revisions are needed to ensure the law is both effective in practice and com - pliant with international and EU standards. Only then can Ukraine claim to have a robust, enforceable and modern sanctions enforcement regime. Prevention of Co-Operation With the Russian Federation’s Accomplices In June 2024, the Main Intelligence Directorate of the Ministry of Defense of Ukraine launched the “Main Portal on Sponsors and Accomplices of Aggression” (the “Portal”). Initially, the Portal contained only two chapters. • Child Kidnappers – is a list of almost 500 individu - als and legal entities involved in the deportation of Ukrainian children. • Components in Weapons – contains data about foreign components in Russian weapons. The chapter contains information about almost 5,000 components, as well as almost 200 weapon units. During the year, the Portal has developed significantly. Seven more chapters have been added. • Instruments of War – is a data portal of foreign equipment used by aggressors in the production of weapons. At the time of writing, almost 1,300 machines have been identified together with 200 factories. • Marine and Aircraft Vessels – contains information about ports, captains involved in the transportation of weapons, stolen Ukrainian products and in the circumvention of sanctions. (a) Currently, the information about almost 1,000 marine vessels and 155 captains has been published. (b) Data about airports and air vessels is expected soon. • Stolen Heritage – provides data not only about Ukrainian works of art, archives and cultural values stolen and destroyed by the aggressor but also about individuals and legal entities involved in such activity. The Main Intelligence Directorate presented information about almost 1,000 objects

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