Please be informed on the latest developments in Ukrainian sanctions policy.
On 14 January 2025, the President of Ukraine submitted a draft law to the Parliament addressing criminal liability for the violation and circumvention of sanctions.
The draft law:
1. Defines the concept of sanctions circumvention.
The range of actions that could be deemed as sanctions circumvention is very broad. Virtually any action aimed at shielding a sanctioned individual from the effects of sanctions could be considered circumvention.
2. Establishes liability for sanctions violations and intentional circumvention.
The penalties are notably severe:
- For individuals: ranging from fines to imprisonment for up to 10 years, accompanied by the confiscation of assets.
- For legal entities: ranging from fines to the dissolution of the entity.
3. Introduces liability for deliberate non-compliance or obstruction of compliance with decisions by the High Anti-Corruption Court enforcing sanctions that involve the confiscation of assets for the benefit of the state.
A reference document regarding the draft law is attached for your review.
Given that the draft law was introduced by the President of Ukraine, we anticipate its adoption without significant delay or substantial amendments.
We will keep you updated once the draft law has been enacted.
