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- Systematic designation of individuals and legal entities.
In Ukraine, the institution of sanctions was introduced in response to the Russian Federation’s illegal annexation of Crimea and the outbreak of armed conflict in the eastern regions of the country.
Taking into account the full-scale invasion of Ukraine by the Russian Federation in 2022, the sanctions policy has become even more stringent.
Ukraine remains the leader in the number of sanctions imposed.
As of now, 18 940 individuals and legal entities have been designated.
Of these, 1 047 individuals and legal entities were sanctioned during the first 6 months of 2025.
The growing number of designations reflects Ukraine’s firm commitment to holding perpetrators to account and disrupting activities that threaten its sovereignty and security.
- Criminalization of Sanctions Violation and/or Circumvention
Despite the fact that the institution of sanctions has existed in Ukraine since 2014, there is still no liability for their violation and/or circumvention.
Since 2020, Ukraine has taken several steps to criminalize sanctions violations and circumvention, but none have been successful.
In January 2025, the President of Ukraine submitted a draft law to Parliament aimed at criminalizing the violation and/or circumvention of sanctions.
Key points of the draft law:
- Definition of notion «circumvention».
A broad range of actions that will constitute sanctions circumvention is defined. In effect, any action aimed at removing an asset worth almost 3000 EUR from the scope of sanctions will be considered as circumvention.
- Introduction of a New Crime: Violation of Sanctions and/or Intentional Circumvention of Sanctions.
The punishment ranges from a fine of almost 8 000 EUR to imprisonment for up to 10 years with disqualification from holding certain positions or engaging in specific activities for 10 to 15 years.
Additional conditions for liability are (a) the aggregate value of the subject of the violation exceeds almost 3 000 EUR; (b) the violation involves military or dual-use goods (regardless of value).
- The possibility for a court to liquidate a legal entity if its authorized person commits a violation or circumvention of sanctions.
Exception – liquidation does not apply to banks.
- Jurisdiction of a new crime falls within the competence of the Security Service of Ukraine.
The draft law enables the conduct of special pretrial investigations (in absentia) and special court proceedings for a new crime.
In June 2025 the draft law passed its first reading. It means that a law will be adopted soon.
While the legislative initiative is a step in the right direction, it still requires significant refinement and expert input – some provisions remain vague or overly broad. This may lead to abuses by judicial authorities and law enforcement agencies.