Digest: Ukrainian Sanctions

April – June 2026

CONTENTS


Sanctions imposed during APRIL – JUNE 2026

During April-June 2026, the President of Ukraine issued nineteen decrees imposing personal sanctions or amending existing sanctions against 184 legal entities, 527 individuals, and 52 vessels.

IssuedSanctioned
19
decrees
184 
legal entities
527 
individuals
52 
maritime vessels

In particular, sanctions were imposed on:

  • individuals and legal entities that facilitate the circumvention of international restrictions, in particular, on manufacturers of components for Kh-101, Kh-59M2/M2A and Iskander-K missiles; entities illegally operating in the temporarily occupied territories and involved in the construction of the Kerch Strait Bridge (Decree No. 294/2026 of 3 April 2026);
  • individuals and legal entities, including companies that produce underwater, surface and aerial unmanned robotic systems and related software; enterprises that manufacture and service weapons (electronic warfare systems, air defence systems, armoured vehicles, submarines, ships, auxiliary fleet vessels, port equipment and related components); aviation industry entities that produce and repair components for the Mi-8, Mi-17, Mi-171, Mi-172, Mi-14 family of helicopters (Decree No. 295/2026 of 3 April 2026);
  • individuals, including commanders of long-range aviation units of the Aerospace Forces of the Russian Federation, commanders of missile and artillery units of the Russian ground forces, who launched strikes using land-based cruise missiles and Iskander-M ballistic missiles (Decree No. 303/2026 of 9 April 2026);
  • individuals, including representatives of the Russian Orthodox Church, who publicly called for the killing of Ukrainians, openly support Russia’s aggression against Ukraine, and use religion to spread propaganda and justify Russia’s invasion of Ukraine (Decree No. 304/2026 of 9 April 2026);
  • individuals involved in organising and participating in the Russian pavilion at the 61st Venice Biennale. Among the sanctioned persons are Anastasiia Karneeva, commissioner of the Russian pavilion; Mikhail Shvydkoi, special representative of the leadership of the Russian Federation for international cultural cooperation; as well as violinist Valeriia Oleinik and singers Illia Tatakov and Artem Nikolaev (Decree No. 305/2026 of 9 April 2026);
  • individuals and legal entities involved in the deportation of children from the temporarily occupied territories of Ukraine and their subsequent ideological indoctrination in the Russian Federation (Decree No. 350/2026 of 29 April 2026);
  • vessels used by the Russian Federation to export oil and petroleum products in circumvention of international restrictions, including vessels sailing under the flags of the Russian Federation and other states, in particular Panama, Barbados, Palau, Marshall Islands, the Comoros, Guyana, Saint Vincent and the Grenadines, Antigua and Barbuda, Madagascar and Mozambique (Decree No. 351/2026 of 29 April 2026);
  • individuals and legal entities, including Belarusian enterprises manufacturing 122 mm and 152 mm artillery shells for the Russian military, as well as persons involved in supporting Russia’s armed aggression against Ukraine (Decree No. 352/2026 of 29 April 2026);
  • individuals, including Ukrainian lawyer Andrii Bohdan and Russian businessman Alan Kiriukhin, who is a key manager of the sanctioned payment system A7A5, used to circumvent sanctions (Decree No. 358/2026 of 2 May 2026). The same Decree also imposed sanctions on Ukrainian businessman and business partner of the sanctioned Viktor Medvedchuk - Bohdan Pukish. However, pursuant to the decision of NSDC of 2 July 2026, enacted by Decree No. 587/2026 of 6 July 2026, Bohdan Pukish was removed from the sanctions list.
  • individuals and legal entities on whom sanctions imposed in 2023 were extended, in particular against Irina Babakova, Natalia Selivanova and Vadim Giner, associated with the operations in Ukraine of the VS Group Management LLC financial and industrial group (Decree No. 378/2026 of 12 May 2026);
  • individuals and legal entities, including companies involved in the supplies for S-300 and S-400 systems, Topol, Yars and Iskander ballistic missiles, gunpowder, rocket fuel, components for ammunition (Decree No. 379/2026 of 12 May 2026);
  • civilian merchant vessels involved in the transportation of cargo for the military needs of the Russian Federation (Decree No. 426/2026 of 23 May 2026);
  • individuals involved in missile strikes against Ukraine, including against critical infrastructure and civilian facilities; in particular, restrictions were imposed on commanders of long-range aviation units of the Russian Aerospace forces whose units launched more than 4,100 Kh-101, Kh-55, Kh-555, Kh-22, Kh-32 air-launched cruise missiles and Kinzhal aero-ballistic missiles (Decree No. 427/2026 of 23 May 2026);
  • individuals and legal entities in accordance with the proposals of the Cabinet of Ministers of Ukraine as a part of the alignment of Ukrainian sanctions against Russia with the 20th package of restrictive measures (sanctions) of the EU (Decree No. 447/2026 of 29 May 2026 and Decree No. 448/2026 of 29 May 2026);
  • individuals and legal entities, including Russian propaganda outlets and judges who issued unlawful decisions regarding Ukrainians (Decree No. 493/2026 of 12 June 2026);
  • legal entities that provide secure communication channels for the occupying forces and occupation authorities and access to the Internet in the temporarily occupied territories of Ukraine for entities serving the Russian Federation (Decree No. 494/2026 of 13 June 2026);
  • individuals and legal entities that support Russia’s armed aggression and serve Russia’s interests in the temporarily occupied territories (Decree No. 501/2026 of 22 June 2026);
  • individuals and legal entities that produce and modernise Russian firearms, create drones and data exchange systems for the occupiers, provide meteorological and information and technical support for Russian aviation (Decree No. 502/2026 of 22 June 2026).

Sectoral sanctions 

On 29 June 2026, a draft resolution on the approval of the decision of the National Security and Defense Council of Ukraine of 9 June 2026 to amend the sectoral sanctions imposed on financial institutions of the Russian Federation was registered with the Verkhovna Rada of Ukraine. On the same day, the decision was enacted by Decree of the President of Ukraine No. 561/2026 and was subsequently approved by the Verkhovna Rada of Ukraine on 14 July 2026. As a reminder, in 2023, sectoral sanctions were imposed for a period of 50 years on all banks, non-bank credit institutions, payment system operators, stock market participants, insurance companies, investment funds and other institutions registered or located in Russia.

The amendments expanded the range of entities subject to sanctions. The expanded list includes operators of information systems where the issuance of digital financial assets is carried out, operators of investment and financial platforms, operators of digital financial asset exchanges, clearing organisations, as well as other providers of financial services infrastructure.

In addition, the following are prohibited:

  • the use of platforms, services and software products of financial institutions of the Russian Federation related to transactions with financial and/or virtual assets;
  • transactions with virtual assets issued by financial institutions of the Russian Federation, virtual assets backed by the Russian rouble, as well as with relevant accounts and wallets;
  • transactions with financial services infrastructure providers, regardless of the country of their registration, if they ensure the execution of transactions with such virtual assets.

The decision also introduces a separate definition of financial services infrastructure providers for the purposes of applying these sectoral sanctions.


Forfeiture of assets of sanctioned persons in favour of Ukraine 

During April-June 2026, the High Anti-Corruption Court (HACC) registered 1 statement of claim for forfeiture of assets in favour of Ukraine, namely case No. 991/4643/26 against Azarov Mykola Yanovych, a former Prime Minister of Ukraine (2010-2014) from the Party of Regions, and his son, Azarov Oleksii Mykolaiovych.

Also, on 28 April 2026, the HACC granted in full 1 statement of claim for forfeiture of assets in favour of Ukraine against Tsariov Oleh Anatoliiovych (a former Ukrainian politician and Member of the Ukrainian Parliament of the IV-VII convocations from the Party of Regions, who after 2014 became a collaborator and one of the main pro-Russian mouthpieces), case No. 991/1705/26.

As a result, in the specified case, the HACC forfeited in favour of the state: 

 21 land plots with a total area of 79.5358 hectares
buildings and structures
with a total area of 3017.2 sq.m. 
 other property, in particular: a 2008 STEMA trailer, and 100% share in the charter capital of GLOU RINO, LLC (identification code 43198486)

The specified decision of the HACC of 28 April 2026 was upheld by the resolution of the Appellate Chamber of the HACC of 4 June 2026.

In June 2026, the State Property Fund of Ukraine (SPFU) published a plan for preparing seven priority assets, inventories and commodities for privatisation and sale. The plan includes both state-owned assets slated for privatization and assets forfeited in favour of the state from sanctioned persons. The list includes: Odesa Portside Plant, JSC, Sumykhimprom, JSC, Demurinsky GZK, LLC, Motordetal-Konotop, LLC, Glukhovo Quartzites Quarry, LLC, Mykolaiv Alumina Refinery Company Limited, Investment Union "Lybid", LLC, bauxite, alumina, iron ore pellets, iron ore briquettes and potassium chloride. Preparation for the auctions began in May-June 2026. The main wave of bidding is scheduled for October-December 2026 through the Prozorro.Sales system.


Challenging sanctions in court

During April-June 2026, the Supreme Court as a court of first instance registered 31 statements of claim seeking to challenge Decrees of the President of Ukraine imposing or amending personal sanctions.

During this period, the Supreme Court rendered decisions in 2 cases challenging sanctions and denied both claims, namely:

  • in case No. 9901/363/21 upon the claim of the Representative Office of Fermak Insaat Taahhut Anonim Sirketi, and 
  • in case No. 990/131/23 upon the claim of SIA ROYAL PAY EUROPE, a Latvian financial company specialising in e-commerce and payment services.

Also, on 31 March 2026, the Supreme Court granted the claim of Verhel Serhii Oleksandrovych (a former Crimean deputy) challenging the sanctions (case No. 990/396/25). The claim was granted because the defendant had failed to provide specific facts (evidence) substantiating the reasons and legal grounds for initiating and imposing sanctions and did not determine the validity period of the sanctions, which is a violation of the principle of legal certainty sensu largo.

The Grand Chamber of the Supreme Court, acting as an appellate court, reviewed and upheld the decisions of the Supreme Court in 2 cases:

  • No. 990/224/23, in which the plaintiff - Radionov Tymur Markovych (a Russian businessman) - was denied the claim to cancel the sanctions;
  • No. 990/109/23, in which the plaintiff – Masliennikov Oleksii Oleksandrovych (a former Metropolitan Joseph of Romny and Buryn) - was denied the claim to cancel the sanctions.

Judicial positions on sanctions issues 

Standards of judicial review in cases challenging sanctions 

Taking into account the ECtHR judgement of 16 October 2025 in the case "M.S.L., TOV v. Ukraine", the Grand Chamber of the Supreme Court, in its resolution of 28 April 2026 in case No. 990/224/23, refined its previous position and set out the standards of judicial review in sanctions cases, which should cover verification of the following aspects:

  1. procedural aspect
    • whether the procedure for adopting a decision on the imposition of sanctions, established by the Constitution of Ukraine and the Law of Ukraine "On Sanctions", was followed;whether the relevant authorities had the power to adopt such a decision;
    • whether the NSDC’s decision was put into effect by the corresponding decree of the President of Ukraine;
  2. factual basis
    • whether the decision on the imposition of sanctions is based on a sufficient factual basis;
    • whether there is evidence capable of supporting with a sufficient degree of persuasiveness the conclusion about the existence of circumstances constituting grounds for imposing sanctions in accordance with the Law of Ukraine "On Sanctions";
  3. legal qualification 
    • whether the established factual circumstances fall under the grounds for imposing sanctions defined by the Law of Ukraine "On Sanctions";
    • whether substantive law was correctly applied;
  4. proportionality
    • whether the applied sanctions are proportionate to the legitimate aim pursued;
    • whether a proper balance is maintained between the adverse consequences for the rights of the individual and the legitimate aim of applying sanctions, taking into account the powers of the NSDC and the President of Ukraine;
  5. absence of arbitrariness
    • whether the decision on the imposition of sanctions is manifestly unreasonable, discriminatory or adopted for a purpose other than that established by law.

State registration of real estate associated with a sanctioned person 

In case No. 260/8508/24, the state registrar denied SOTRA HOLDING AG the registration of title on the basis of a court decision, since the ultimate beneficial owner (UBO) of the current owner of the real estate - Terminal Karpaty, LLC - is under Ukrainian sanctions.

In the resolution of 1 May 2026 in case No. 260/8508/24, the Supreme Court recognised the conclusions of the lower courts on the legality of such denial as premature, cancelled their decisions and remitted the case for a new trial. At the same time, the Supreme Court noted that the case in which a decision was made to recognise the title of SOTRA HOLDING AG, was initiated long before the imposition of sanctions on the UBO of the current owner of the real estate, and SOTRA HOLDING AG (its shareholders / UBOs) is not under sanctions.

Given this, the Supreme Court concluded that, when considering similar cases, the following matters shall be determined:

  • whether such state registration may affect the national interests of Ukraine, taking into account the aim of applying sanctions in accordance with the Law of Ukraine "On Sanctions";
  • the grounds and date of acquisition of ownership rights to the real estate object by the new owner;
  • the proportionality of state interference in the right of the new owner to peaceful possession of property.

A different (formal) approach to resolving such disputes, according to the conclusions of the Supreme Court, will not ensure effective protection of the violated rights of the initiator of the judicial process.


Legislative changes


During April–June 2026, a number of regulatory acts were adopted that directly regulate the implementation of sanctions or require sanctions restrictions to be taken into account in the procedures of asset management, eligibility for state support, competitive selection procedures and execution of state contracts. Among them, special attention should be paid to the following: 

  1. Order No. 682 of the State Property Fund of Ukraine of 14 April 2026, registered with the Ministry of Justice of Ukraine on 29 April 2026 under No. 586/45980, approved the Regulation on the Activities of the Auction Commission of the SPFU on the Sale of Assets Forfeited in Favour of the State under the Law of Ukraine "On Sanctions". The Regulation provides that the commission is established for each individual asset subject to sale and consists of at least five representatives of the Fund. Its main powers include establishing the starting price of the asset, developing additional terms of sale, determining the date of the auction and preparing a draft announcement of the auction.
  2. Decision No. 09/21/4585/K03 of the National Securities and Stock Market Commission of 10 June 2026, registered with the Ministry of Justice of Ukraine on 18 June 2026 under No. 889/46283, approved amendments to the Procedure for the Implementation by Capital Markets Participants of Decisions of the NSDC on the Imposition of Sanctions. In particular, the amendments clarify the procedure for executing both new sanctions decisions and decisions on amending already applied sanctions, introduce a mechanism for completing clearing and depository settlements for transactions initiated before the sanctions came into force, and also determine a separate procedure for actions in the event of application of sanctions directly to the depository institution, including the obligation to suspend depository transactions and inform clients and regulators. In addition, the amendments provide for the possibility of the NSSMC issuing individual permits to perform specific actions subject to sanctions restrictions.
  3. A number of regulatory acts established or clarified restrictions / prohibitions regarding the activities of sanctioned persons, namely, sanctioned persons cannot be:

International sanctions 

During April–June 2026, the international sanctions coalition against Russia continued to increase pressure on several fronts. In particular:


The European Union 
  • On 23 April 2026, the Council of the European Union adopted the 20th package of sanctions against Russia. The package covers 120 new listings of individuals and entities and introduces multi-tiered sectoral restrictions targeting the energy, banking sector, crypto-assets, the military-industrial complex and trade. The economic restrictions of the package, in particular, are implemented by Council Regulation (EU) No. 2026/506. Among other things, the ban on transactions was extended to 20 Russian banks and four financial institutions in third countries, 46 vessels of the "shadow fleet" were added to the sanctions list, and a sectoral ban was introduced on providers and platforms established in Russia and intended for the transfer and exchange of crypto assets. A further 58 entities associated with the Russian military-industrial complex were added to the list of entities subject to tightened export restrictions.
  • On 9 June 2026, President of the European Commission Ursula von der Leyen proposed the 21st package of sanctions. The proposed restrictions would target the energy and financial sectors, crypto assets, trade, the "shadow fleet" and other mechanisms for circumventing sanctions. It was also proposed to ban entry into the EU for persons who served in the Armed Forces of the Russian Federation after the start of the full-scale invasion.
  • On 25 June 2026, the EU Council extended the sectoral economic sanctions against the Russian Federation for another 12 months - until 31 July 2027.

The United Kingdom 
  • On 11 May 2026, the United Kingdom made 85 new sanctions designations. Of these, 29 concerned individuals and organisations involved in the forced displacement, re-education and militarisation of Ukrainian children, while the remaining 56 targeted individuals and organisations involved in Russian information operations and the spread of propaganda.
  • On 16 June 2026, the United Kingdom announced 70 new sanctions designations and measures aimed at the Russian "shadow fleet", supply chains for the military-industrial complex and financial networks used to circumvent international restrictions. In particular, sanctions were applied to more than 20 oil tankers, vessels associated with the Arctic LNG 2 project, as well as insurance companies and other maritime service providers.

Canada 
  • On 8 May 2026, Canada imposed sanctions on 23 individuals and 5 entities involved in the unlawful deportation or forced displacement, indoctrination and militarisation of Ukrainian children in the Russian Federation and in the temporarily occupied territories of Ukraine.
  • On 12 June 2026, Canada introduced a new package of sanctions against 7 individuals, 34 legal entities and 121 vessels of the Russian "shadow fleet". The restrictions are directed, in particular, against representatives of the Russian military-industrial and nuclear sectors, manufacturers of drones and aviation equipment, financial networks and crypto-assets channels that help Russia finance the war and circumvent sanctions.

The United States 
  • On 4 June 2026, the US House of Representatives, by a vote of 226 to 195, passed Bill H.R. 2913 - Ukraine Support Act. The bill provides for further security support for Ukraine and the imposition of additional sanctions if the Russian Federation continues the war or refuses to engage in good-faith peace negotiations. Potential restrictions cover Russian financial institutions and the energy sector, the "shadow fleet", individuals involved in the construction and maintenance of the Kerch Strait Bridge, assisting North Korea’s participation in the war and kidnapping Ukrainian children. The bill also provides for tightened export controls and the possibility of imposing higher tariffs on Russian goods.

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