On 12 September 2014, the Law of Ukraine “On sanctions” (the “Law”) came into force.

The Law provides a mechanism for reaction to existing and potential threats to the national interests and security of Ukraine and provides for the potential imposition of sanctions.

The sanctions could be imposed on a foreign state, a foreign legal entity, a legal entity being under the control of a foreign legal entity or a foreign individual, foreigners, stateless persons and other entities engaged in terrorism. However, the Law does not apply to Ukrainian legal entities and the citizens of Ukraine.

The Law offers 25 types of sanctions, including: freezing of company’s assets, restricting certain trade operations and cancellation or suspension of a company’s licenses.

When determining whether or not a sanction should be imposed on foreign state or unspecified range of persons (sectorial sanctions), the decision must be adopted by the National Security and Defence Council of Ukraine, introduced by a Decree of the President of Ukraine and approved by the Parliament of Ukraine.

Sanctions against foreign legal entities or individuals (individual sanctions), are only to be imposed when they have been adopted by the National Security and Defence Council of Ukraine and further approved by the President of Ukraine.