Ukrainehas imposed sanctions against 388 individuals and 105 companies in connectionwith Russian aggression in Eastern Ukraine and Crimea. 
The sanctions are introduced for a period of one year and were enacted on 16September 2015 when the President of Ukraine enacted1 the decisionof the National Security and Defense Council of Ukraine of 2 September 2015.

What sanctions wereintroduced?

The Security Council introduced personal economic sanctions againstspecifically named individuals and legal entities.  No sectoral sanctionswere introduced. 

Various types of sanctions apply to specific legal entities and individuals.The list of sanctions includes such measures as freezing assets, restrictionson trade operations, restrictions on exit of capital from Ukraine, suspensionof performance of economic and financial obligations, prohibition onparticipation in public procurement, denial and cancellation of visas,prohibition on entering Ukraine and other restrictions.

Against Whom?


The sanctions were introduced against citizens of Russia, Ukraine, Poland, theUnited Kingdom, Italy, Greece, Serbia, Spain, France, Bulgaria, Israel, etc.The list of individuals includes MPs, high ranking government and stateofficials of Russia, MPs from Greece, Italy, Serbia, Hungary, etc.

Corporations and Organizations

The sanctions apply to 105 legal entities, mostly Russian legal entities andsome illegal militarized organizations operating in Eastern Ukraine.

The sanctions applicable to Russian legal entities and their subsidiaries inUkraine extend to the following sectors:  

• Bankingand 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, RossiyaAirlines, Yamal, Rusline, Donavia, Polet and others;

• Telecommunication:NTV, Rossiya 24, RTR Planeta, Pervyy Channel and others;

• IT:Dr. Web, Kaspersky Lab; and

• Military-industrialcomplex: Russian Helicopters, Almaz-Antey, Helicopter ServiceCompany, Ulan-Ude Aviation Plant and others.

Afull list of legal entities and individuals subject to sanctions is given inthe annexes to the Decree.

Any counterparty dealing with entities or individuals on the sanctions listmust carefully assess the exact scope of sanctions imposed and the implicationsof dealing with such entities and individuals. 

Aspreviously announced, Baker & McKenzie has set up a dedicated blog,accessible on, toprovide real-time updates on international sanctions and critical developmentsin the Ukraine crisis from an international trade compliance perspective.

 1 PresidentialDecree No. 549/2015 approving the Decision of the National Security and DefenseCouncil of Ukraine dated 2 September 2015 (the “Decree”).


ThisLEGAL ALERT is issued to inform Baker & McKenzie clients and otherinterested parties of legal developments that may affect or otherwise be ofinterest to them. The comments above do not constitute legal or other adviceand should not be regarded as a substitute for specific advice in individualcases.