On 23 March 2021, the president of Ukraine enacted Presidential Decree No. 109/2021 dated 23 March 2021 “On the Decision of the National Security and Defense Council of Ukraine dated 23 March 2021 On Imposition, Cancellation and Amendment of Personal Special Economic and Other Restrictive Measures (Sanctions),” effective from 25 March 2021 (“Sanctions Decision”) imposing personal special economic and other restrictive measures (sanctions) against almost 80 Russian companies, 23 Russian individuals and three Members of the European Parliament.

The sanctions are effective for a period of between three and five years and target the following persons, among others:

  • Russian oil and gas companies, as well as companies in other sectors, using the property of Ukrainian companies and state property of Ukraine located in Crimea that were illegally expropriated by the Russian authorities
  • Russian insurance companies, including Insurance Company Arsenal LLC and Rosgosstrakh PJSC
  • Russian construction companies involved in the construction of the Crimean Bridgebetween the Krasnodar region in Russia and Crimea
  • Russian internet propaganda media companies, including Internet-Pressa (svpressa.ru), TV-Novosti (rt.com), Gazeta.Ru JSK (gazeta.ru), Lenta.Ru LLC (lenta.ru), Federal News Agency LLC (jpgazeta.ru, dnronlane.su, i-don.ru, dnr24.su, etc.), Utro.Ru LLC (utro.ru), International News Agency Rossiya Segodnya (ukraina.ru), Russian News Agency TASS (tass.ru) and other companies associated with online media resources
  • Russian individuals — officials of the Ministry of Internal Affairs of Russia responsible for the migration policy, representatives of Russian intelligence, migration authorities, as well as Russian individuals wanted by the FBI for cybercrimes
  • French nationals — Members of the European Parliament Virginie Joron, Lacapelle Jean-Lin and Olivier Philippe — for visiting Crimea in violation of the Ukrainian border regime

The Sanctions Decision imposes a broad set of restrictions on the sanctioned companies and individuals, including the following:

  • assets freeze
  • restriction on trade transactions
  • restriction on the withdrawal of capital from Ukraine
  • restriction on the provision of telecommunication services and the use of public telecommunication networks by the media companies
  • restriction on access to the internet resources/servers of the media companies
  • suspension of performance of economic and financial obligations
  • complete prohibition of transactions with respect to securities of the companies on the sanctions list
  • cancelation or suspension of licenses and other permits required for a certain type of business activity
  • visa restrictions and other prohibitions on foreign individuals entering Ukraine

The full list of legal entities and individuals subject to sanctions is set forth in the annexes to the Sanctions Decision.

Any counterparty dealing with entities or individuals on the sanctions lists must carefully assess the exact scope of the sanctions applicable and the implications of dealing with sanctioned entities and individuals.

Author: Anna Shtepa.