Digest: Ukrainian Sanctions

Sanctions imposed during October–December 2025

During October-December 2025, the President of Ukraine issued 17 decrees on the imposition of (amendments to) personal sanctions.

Issued	Sanctioned
17 decrees	257 legal entities	163 individuals	712 vessels

In particular, sanctions were imposed on:

individuals and legal entities associated with the oil sector of the Russian Federation who finance the continuation of the war against Ukraine, in particular, sanctions were imposed on Nefteavtomatika, JSC and Kurgan Plant of Chemical Machine Building, LLC (Decree No. 747/2025 of 4 October 2025);
individuals and legal entities associated with the Russian military-industrial complex, in particular, sanctions were imposed on Shpantekh, LLC and Opto-Mechanical Design Bureau "Valday", JSC (Decree No. 748/2025 of 4 October 2025);
legal entities associated with the sanctioned Russian billionaires Petr Aven, Mikhail Fridman, and Andrei Kosogov (Decree No. 749/2025 of 4 October 2025);
individuals and legal entities from China, Kazakhstan, Turkey, Seychelles and Russia who provide the Russian Federation with profits, supply weapons and equipment, within the framework of sanctions synchronised with Japan (Decree No. 778/2025 of 11 October 2025);
individuals who justify the armed aggression of the Russian Federation and deny the occupation of Ukrainian territories and receive funding from profits of the coal industry in the temporarily occupied territory of Donbas (Decree No. 810/2025 of 31 October 2025);
individuals and legal entities that are manufacturers and suppliers of the Russian military-industrial complex (Decree No. 811/2025 of 31 October 2025);
individuals and legal entities working on resource extraction in the Arctic and ensuring the extraction / export of Russian energy resources, as well as developers and manufacturers of military engineering equipment (Decree No. 819/2025 of 6 November 2025);
individuals and legal entities in accordance with proposals of the Cabinet of Ministers of Ukraine regarding synchronisation of Ukrainian sanctions against Russia with the 19th package of restrictive measures (sanctions) of the EU (Decree No. 820/2025 of 6 November 2025);
individuals who appropriated assets of the agricultural sector, grain crops, cultural heritage objects, and participated in information operations against Ukraine (Decree No. 834/2025 of 9 November 2025);

legal entities that actively disseminated propaganda, justified the aggression of the Russian Federation against Ukraine and formed anti-Ukrainian sentiments both in Russia and in the temporarily occupied territories of Ukraine (Decree No. 835/2025 of 9 November 2025);
co-owner of the Studio "Kvartal 95" Tymur Mindich, and businessman Oleksandr Tsukerman (Decree No. 843/2025 of 13 November 2025);
maritime vessels which in 2022-2025 illegally entered ports of Ukraine temporarily occupied by Russia and exported Ukrainian food products (Decree No. 860/2025 of 25 November 2025);
legal entities associated with the energy sector, among them Rosneft, as well as companies belonging to the Lukoil group, within the framework of sanctions synchronised with the U.S. (Decree No. 870/2025 of 29 November 2025);
individuals and legal entities involved in the development and production of reconnaissance and strike UAVs, FPV drones and unmanned aerial systems (Decree No. 871/2025 of 29 November 2025);
maritime vessels that are part of the "shadow fleet" of the Russian Federation and through which Russia circumvented sanctions of the EU, G7 and other states, thereby exporting oil, petroleum products and liquefied gas (Decree No. 929/2025 of 13 December 2025);
individuals and legal entities associated with the forced deportation of Ukrainian children, as well as with the supply to the Russian Federation of electronics and dual-use components used for the production of missiles and drones, within the framework of sanctions synchronised with the UK (Decree No. 997/2025 of 26 December 2025);
individuals belonging to the military leadership of South Sudan, in accordance with resolutions of the United Nations Security Council and the decision of the Council of the European Union regarding the situation in the Republic of South Sudan (Decree No. 998/2025 of 26 December 2025).

State Registry of Sanctions in Ukraine

As of 31 December 2025, the State Registry of Sanctions contained information on:


34 953 sanctions actions (imposing, amending, cancelling sanctions)	9 129 sanctioned legal entities
12 510 sanctioned individuals	712 sanctioned vessels

Forfeiture of assets of sanctioned persons in favour of Ukraine

During October-December 2025, the High Anti-Corruption Court (HACC) registered 2 statements of claim for forfeiture of assets in favour of Ukraine (cases No. 991/10154/25 and No. 991/12957/25). Also, during this period, HACC fully granted 3 statements of claim for forfeiture of assets in favour of Ukraine against the following persons:

Zakharchenko Vitalii Yuriiovych (Minister of Internal Affairs of Ukraine in 2011-2014, owner of the closed pro-Russian propaganda TV channel KRT), case No. 991/10013/25;
Gomselmash, OJSC (Belarusian enterprise, manufacturer of agricultural machinery), case No. 991/10154/25;
Kabargin Serhii Leonidovich (Russian businessman, co-owner of the Russian holding "Titan-2"), case No. 991/9917/25.

As a result, during October-December 2025, the HACC forfeited in favour of the state:

funds on accounts in Ukrainian banks
totalling more than UAH 157,617.16;

residential and non-residential real estate objects,
namely 3 non-residential premises with a total area of
375.78 sq.m. and 3 apartments;

corporate rights (shares in authorised capitals): 100% in SUNN DE LION, LLC, and Trading House Gomselmash-Ukraine, LLC, 50% in Promin-Yug, LLC, 12.86% in Trading House MTZ-Belarus-Ukraine, LLC, as well as 52.7595% of shares in Kirovohrad Mining Administration, JSC;

intellectual property rights to 5 international trademarks
belonging to Gomselmash, OJSC.

Challenging sanctions in court

During October-December 2025, the Supreme Court registered 18 statements of claim seeking to challenge Decrees of the President of Ukraine imposing (amending) personal sanctions issued after the full-scale invasion.

Within this period, the Supreme Court considered one (1) case challenging sanctions, namely, denied the claim filed by Double-U Net Ukraine, LLC (Ukrainian telecommunications company), case No. 990/326/24.

Legislative changes

Between October and December 2025, a number of draft bills relating to Ukrainian sanctions legislation were adopted and registered, and amendments were made to by-laws. Among them, special attention should be paid to the following:

On 8 October 2025, the Ministry of Health of Ukraine (MoH) adopted Order No. 1529, which set out in a new wording the Procedure for the implementation of types of sanctions in the healthcare sector and monitoring their effectiveness, approved by Order No. 1710 of 21 September 2022.

The aim of the changes is to align the Procedure with the requirements of the current legislation. In particular, the list of persons responsible for ensuring the implementation of sanctions and monitoring their effectiveness has been expanded. In particular, now it encompasses employees of central executive bodies whose activities are coordinated by the MoH. Also, the heads of central executive bodies have been added to the participants in the process of ensuring the implementation of sanctions. Instead of a list of all types of sanctions, the Procedure contains a direct reference to Article 4 of the Law of Ukraine "On Sanctions" and establishes a rule regarding the use by responsible persons of the State Registry of Sanctions to obtain up-to-date information on sanctioned persons. In addition, the document clarifies the procedure for sending the results of monitoring the effectiveness of sanctions to the Cabinet of Ministers of Ukraine, the National Security and Defense Council of Ukraine and relevant state authorities.
On 22 October 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 1335, approving “The Procedure for the Formation and Maintenance of an Open List of Software and Communication (Network) Equipment Prohibited for Use” (Resolution). This Resolution was adopted to implement Article 4 of the Law of Ukraine "On the Fundamental Principles of Ensuring Cybersecurity of Ukraine".

Under the Resolution, the State Service of Special Communications and Information Protection is tasked with forming and maintaining the list of software and communication (network) equipment prohibited for use (List).

Software products and equipment are included in the List if the ultimate beneficial owner of the business entity, participant of the legal entity, author of the software (holding proprietary rights), or person holding proprietary rights to at least one element of the software or communication (network) equipment is an individual or legal entity subject to (1) Ukrainian sanctions, (2) international sanctions recognised by Ukraine, or on the basis of a relevant court decision.

The Resolution also determines the grounds for removal from the List and/or amendment of the information contained therein, which include: cancellation or modification of Ukrainian or international sanctions, correction of technical errors made when entering information into the List, and court decision.
On 28 November 2025, Draft Bill No. 14266 was registered, proposing amendments to certain Ukrainian laws on residential properties (apartments) forfeited to the state pursuant to a court decision imposing a respective sanction.

The primary purpose of the draft bill is to enable the State Property Fund of Ukraine to sell residential properties (apartments) forfeited to the state pursuant to a court decision imposing a sanction under paragraph 1-1 of part 1 of Article 4 of the Law of Ukraine “On Sanctions”. If adopted, the proposed amendments would provide the state with a legal mechanism for the swift sale of forfeited apartments and houses by way of auction, thereby contributing to the state budget.
On 8 December 2025, Draft Bill No. 14281 proposing amendments to the Customs Code of Ukraine and the Law of Ukraine "On Sanctions" to regulate the disposal of assets (foreign goods and vehicles) subject to asset forfeiture in favour of the state. In particular, the draft bill provides for the automatic termination of customs regimes (such as transit, temporary admission, customs warehouse, etc.) in respect of goods and commercial transport that have been forfeited by a court decision in accordance with paragraph 1-1 of Part 1 of Article 4 of the Law of Ukraine "On Sanctions". At the same time, the previous owner (declarant) is exempted from the obligation to pay customs duties for such forfeited goods.

Adoption of the draft bill would resolve the issue of releasing into free circulation within the customs territory of Ukraine goods forfeited to the state in accordance with Article 1-1 of the Law of Ukraine "On Sanctions".