Ukraine has imposed sanctions against 388 individuals and 105 companies in connection with Russian aggression in Eastern Ukraine and Crimea. The sanctions are introduced for a period of one year and were enacted on 16 September 2015 when the President of Ukraine enacted1 the decision of the National Security and Defense Council of Ukraine of 2 September 2015.
What sanctions were introduced?
The Security Council introduced personal economic sanctions against specifically named individuals and legal entities. No sectoral sanctions were introduced. Various types of sanctions apply to specific legal entities and individuals. The list of sanctions includes such measures as freezing assets, restrictions on trade operations, restrictions on exit of capital from Ukraine, suspension of performance of economic and financial obligations, prohibition on participation in public procurement, denial and cancellation of visas, prohibition on entering Ukraine and other restrictions.
Individuals The sanctions were introduced against citizens of Russia, Ukraine, Poland, the United Kingdom, Italy, Greece, Serbia, Spain, France, Bulgaria, Israel, etc. The list of individuals includes MPs, high ranking government and state officials of Russia, MPs from Greece, Italy, Serbia, Hungary, etc. Corporations and Organizations The sanctions apply to 105 legal entities, mostly Russian legal entities and some illegal militarized organizations operating in Eastern Ukraine. The sanctions applicable to Russian legal entities and their subsidiaries in Ukraine extend to the following sectors:
- Banking and finance: Moscow Bank, Gazprom Bank, Genbank, Adelantbank, Smartbank, Marshall Capital Partners, Russian National Commercial Bank, Tempbank and others;
- Aviation: Aeroflot, Transaero, Ural Airlines, Gazprom Avia, Sirius-Aero, Rossiya Airlines, Yamal, Rusline, Donavia, Polet and others;
- Telecommunication: NTV, Rossiya 24, RTR Planeta, Pervyy Channel and others;
- IT: Dr. Web, Kaspersky Lab; and
- Military-industrial complex: Russian Helicopters, Almaz-Antey, Helicopter Service Company, Ulan-Ude Aviation Plant and others.
A full list of legal entities and individuals subject to sanctions is given in the annexes to the Decree. Any counterparty dealing with entities or individuals on the sanctions list must carefully assess the exact scope of sanctions imposed and the implications of dealing with such entities and individuals. As previously announced, Baker & McKenzie has set up a dedicated blog, accessible on http://www.bakermckenzie.com/sanctionsnews/, to provide real-time updates on international sanctions and critical developments in the Ukraine crisis from an international trade compliance perspective. ________________________________________ 1 Presidential Decree No. 549/2015 approving the Decision of the National Security and Defense Council of Ukraine dated 2 September 2015 (the “Decree”).