According to media reports, on 22 October 2018 Vladimir Putin signed the Decree on Imposing Special Economic Measures Triggered by Unfriendly Actions of Ukraine against Citizens and Legal Entities of the Russian Federation.

According to the available text of the Decree, it was issued in response to “unfriendly actions of Ukraine contradicting international law, which concern imposition of the restrictive measures against the citizens and legal entities of the Russian Federation and with the aim to protect the national interests of the Russian Federation”.

The Decree orders the Russian government to do the following: draw up a list of Ukrainian individuals and legal entities to be sanctioned; determine the specific measures to be imposed; and secure other necessary measures to implement the Decree.

The Decree entered into legal effect on the date of its signing and will remain in effect until Ukraine cancels the restrictive measures “imposed in relation to the citizens and legal entities of Russian Federation”.

It is not yet know what kind of economic sanctions the Russian government will impose and who in Ukraine will be targeted by such sanctions. These sanctions, however, are expected to directly affect the flow of funds and goods from Russia to Ukraine as well as hamper bilateral economic relations between the two countries.

We will monitor any further actions taken by the Russian government in connection with the Decree and the possible impact of these actions on business and Ukraine-Russia cross-border economic activities.

Legislation: Decree on Imposing Special Economic Measures Triggered by Unfriendly Actions of Ukraine against Citizens and Legal Entities of the Russian Federation, dated 22 October 2018