October 2025 – Ukraine currently
maintains one of the largest sanctions lists in Europe, comprising
roughly 21,000 entries but with only 114 removals over the past
decade. Sanctions have become a central instrument of national
security policy in response to persistent external threats. At the
same time, the likelihood of successfully overturning a designation
remains extremely limited.
How sanctions are imposed
Under current law, the National Security and Defense Council of
Ukraine (the “NSDC”) is the primary body responsible
for initiating and approving sanctions proposals. These proposals
may originate from the President, the Verkhovna Rada of Ukraine
(Ukraine's parliament), or other state authorities such as
the Cabinet of Ministers, the Security Service of Ukraine or the
National Bank of Ukraine, but they must pass through the NSDC
before enactment.
