Digest: Ukrainian Sanctions

Sanctions imposed during January – March 2026

During January – March 2026, the President of Ukraine issued eighteen decrees on the imposition of (amendments to) personal sanctions against 277 legal entities, 672 individuals, and 91 maritime vessels.

Issued	Sanctioned
18 decrees	277 legal entities	672 individuals	91 vessels

In particular, sanctions were imposed on:

individuals and legal entities involved in servicing the state defence order of the Russian Federation and the activities of its military-industrial complex (Decree No. 8/2026 of 3 January 2026);
individuals and legal entities who use sports venues to disseminate anti-Ukrainian narratives and Russian propaganda (Decree No. 60/2026 of 17 January 2026);
individuals and legal entities servicing the tanker fleet of the Russian Federation and transporting sanctioned oil, as well as Kremlin propagandists and individuals involved in cyberattacks against Ukraine as well as EU and NATO member states (Decree No. 86/2026 of 30 January 2026);
individuals and legal entities within the framework of sanctions synchronised with the United Kingdom, as well as extension of Ukrainian sanctions that were about to expire, in particular against former oligarch Dmytro Firtash (Decree No. 94/2026 of 2 February 2026);
individuals and legal entities, in particular former Member of Parliament and businessman Taras Kozak and companies associated with him, against whom sanctions were extended (Decree No. 95/2026 of 2 February 2026);
individuals and legal entities involved in the production of Russian missiles and drones, as well as financial structures that assist the Russian Federation in circumventing international restrictions (Decree No. 102/2026 of 7 February 2026);
individuals and legal entities that are settlement operators, crypto asset holders, crypto exchangers and structures associated with the Russian crypto market and mining (Decree No. 103/2026 of 7 February 2026);
maritime vessels belonging to the “shadow fleet” of the Russian Federation (Decree No. 121/2026 of 12 February 2026);
individuals who are Russian athletes supporting the war and organising events for Ukrainian children abducted by the Russian Federation (Decree No. 123/2026 of 16 February 2026);

President of Belarus Alexander Lukashenko for assisting Russia in the war against Ukraine (Decree No. 125/2026 of 18 February 2026);
individuals and legal entities that supply, develop, manufacture and repair equipment, electronic warfare systems and spare parts for the needs of the Russian military-industrial complex (Decree No. 130/2026 of 21 February 2026);
individuals who are captains of “shadow fleet” vessels exporting Russian petroleum products (Decree No. 131/2026 of 21 February 2026);
Russian scientists, heads of occupation administration bodies and organisations that support Russian aggression, disseminate propaganda and are involved in the distortion of history, theft of cultural valuables and documents of the National Archival Fund of Ukraine (Decree No. 161/2026 of 24 February 2026);
legal entities that ensure the delivery of goods to and from the temporarily occupied territories of Ukraine ( Decree No. 212/2026 of 27 February 2026);
legal entities, against which sanctions imposed in 2021 and 2023 were extended, engaged in the repair and maintenance of aviation equipment, companies developing and manufacturing drones, as well as enterprises that operate illegally in the temporarily occupied Crimea and were involved in the construction of the Crimean (Kerch) Bridge (Decree No. 231/2026 of 10 March 2026);
individuals who rendered unlawful sentences on imprisonment of prisoners of war, support and justify Russian aggression against Ukraine (Decree No. 232/2026 of 10 March 2026);
individuals and legal entities that launched, deployed and scaled the production of “Shahed” drones in the Russian Federation (Decree No. 243/2026 of 14 March 2026);
individuals – Paralympic athletes – who are disseminating Russian propaganda and using sporting events as a platform for whitewashing Russian crimes and the occupation (Decree No. 244/2026 of 14 March 2026);

State Registry of Sanctions in Ukraine

As of 31 March 2026, the State Registry of Sanctions contained information on:


35 993 sanctions actions (imposing, amending, cancelling sanctions)	9 373 sanctioned legal entities
13 180 sanctioned individuals	803 sanctioned maritime vessels

Forfeiture of assets of sanctioned persons in favour of Ukraine

During January – March 2026, the High Anti-Corruption Court (HACC) registered 2 statements of claim for forfeiture of assets in favour of Ukraine (cases No. 991/411/26 and No. 991/1705/26).
Also, during this period, HACC fully or partially granted 3 statements of claim against the following individuals and legal entities:

Kevorkian Kostiantyn Ervantovych (former deputy of the Kharkiv City Council of the 6th convocation from the “Party of Regions”, pro-Russian propagandist), case No. 991/10090/25;

Gamzalov Stanislav Dzhakhparovych (Russian businessman, owner of companies supplying goods for the military-industrial complex of the Russian Federation), case No. 991/12957/25;

Aviakor - Aviation Plant, JSC (an enterprise of the Russian military-industrial complex providing logistical support for the armed aggression of the Russian Federation against Ukraine), case No. 991/411/26.

During January – March 2026, the Appellate Chamber of the HACC reviewed 1 decision of the HACC on the imposition of a sanction in the form of forfeiture of assets in favour of Ukraine, namely in case No. 991/10090/25.

As a result, during January – March 2026, the HACC and the Appellate Chamber of the HACC forfeited in favour of the state:


	corporate rights: 25% of shares in Kryukovsky Railway Car Building Works, JSC, with a nominal value of UAH 21,502,416.75; 15% interest in the authorised capital of PERSHOSTOLYCHNE, LLC; 60% interest in the authorised capital of SALES DEPARTMENT "KhK", LLC; 60% interest in the authorised capital of PUBLISHING HOUSE "KhK", LLC; 30% interest in the authorised capital of KHARPOL, LLC; 100% interest in the authorised capital of PUBLISHING COMPANY KhK, LLC; 60% interest in the authorised capital of MAIN PUBLISHING COMPANY "KhK", LLC;
	5 real estate objects
	aviation assemblies and parts of the AN-140-100 aircraft structure (fuselage assembled with the centre section, vertical tail, door locking system, landing gear, aircraft systems from unfinished works, etc.);
	vehicles (two VAZ 2109 automobiles);
	funds in the amount of USD 627.53;
	property rights to trademarks.

Challenging sanctions in court

During January – March 2026, the Supreme Court registered 10 statements of claim seeking to challenge Decrees of the President of Ukraine imposing (amending) personal sanctions issued after the full-scale invasion.

During this period, the Supreme Court rendered decisions in 2 cases challenging sanctions, imposed since the start of Russia’s full-scale invasion of Ukraine, in which the claims were denied, namely:

No. 990/164/24 – upon the claim of Havryliuk Valerii Vasyliovych
(owner of the corporations “Lennord” and Zavod “Kvarts”, Additional Liability Company);
No. 990/135/25 – upon the claim of Proteas Management Services Ltd (Cypriot company providing administrative services (maintaining registers of shareholders and directors of companies, provision of a registered address, provision of nominee director and nominee shareholder services, filing of reports).

Legislative changes

Between January and March 2026, a number of draft bills relating to Ukrainian sanctions legislation were registered, and regulatory acts were adopted. Among them, special attention should be paid to the following:

On 23 January 2026, Draft Bill No. 14396 on amendments to the Customs Code of Ukraine Regarding Certain Issues in Connection With the Imposition of Sanctions was registered for the purpose of proper enforcement of decisions on Ukrainian sanctions.

The draft bill proposes to establish automated exchange of information on the imposition of sanctions and establishment of the ownership structure of a legal entity through electronic information interaction between customs authorities and the holders of the State Registry of Sanctions and the Unified State Registry of Legal Entities, Individual Entrepreneurs and Public Organisations; to define a clear procedure for actions of customs authorities during the performance of customs formalities and their decision-making in the event of the imposition of sanctions in accordance with the Law of Ukraine “On Sanctions”.
By Resolution No. 310 of the Cabinet of Ministers of Ukraine of 12 March 2026, the Procedure for the Implementation of the Pilot Project on the Development of Military-Purpose Goods in the Field of Artificial Intelligence Technologies was approved. In accordance with the said Resolution, companies are not eligible to participate in the pilot project where Ukrainian or international sanctions have been imposed either on the company itself or on its participants (founders or shareholders) or ultimate beneficial owners.
Also, Resolution No. 324 of the Cabinet of Ministers of Ukraine of 12 March 2026 introduced amendments to the Asset Valuation Methodology. In particular, the Methodology has been supplemented with provisions establishing specific rules for the valuation of assets in respect of which a court has issued a decision on imposition of the sanction of forfeiture of assets in favour of Ukraine.
On 27 March 2026, the Procedure for the Implementation of Types of Sanctions and Monitoring of Their Effectiveness by the State Agency of Ukraine PlayCity, approved by Order No. 16-OD of the State Agency of Ukraine PlayCity of 12 February 2026, entered into force.
It was adopted for the purpose of implementing an effective state sanctions policy in the field of organisation and conduct of gambling and in the lottery sector.
On 21 January 2026, the Cabinet of Ministers of Ukraine, by Resolution No. 75, approved the Procedure for the Disposal of Assets in Respect of Which a Court Decision on the Imposition of the Sanction Provided for in Paragraph 1-1 of Part 1 of Article 4 of the Law of Ukraine “On Sanctions” has been adopted. From now on, the disposal of assets forfeited in favour of the state shall be carried out by means of electronic auctions on the Prozorro.Sales ETS. All funds received from the sale of sanctioned property shall be credited to the state budget with subsequent allocation to the fund for the liquidation of the consequences of armed aggression. It should be noted that the Resolution, which entered into force on 1 February 2026, is of a temporary nature and shall cease to be effective one year after the termination or cancellation of martial law.
On 5 February 2026, the Cabinet of Ministers of Ukraine adopted a number of resolutions aimed at aligning the activities of ARMA (Asset Recovery and Management Agency) with European standards of transparency, accountability and efficiency. In particular, Resolution No.167 “Certain Issues Regarding the Selection of a Manager of a Complex Asset (Assets)" and No.166 “Certain Issues Regarding the Selection of a Manager of a Simple Asset (Assets)" of the Cabinet of Ministers of Ukraine introduced procedures for the selection of managers for “simple” and “complex” assets: persons against which, or against whose ultimate beneficial owners, Ukrainian or international sanctions have been imposed shall not be admitted to the selection process.

Digest: Ukrainian Sanctions

January – March 2026

CONTENTS

Sanctions imposed during January – March 2026

State Registry of Sanctions in Ukraine

Forfeiture of assets of sanctioned persons in favour of Ukraine

Challenging sanctions in court

Legislative changes

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