The Ukrainian sanctions list is a legally binding register of individuals and entities subject to restrictive measures under Ukrainian law. Foreign businesses often focus on EU, US, or UK sanctions — but Ukraine operates its own autonomous sanctions regime, and it affects who you can legally transact with inside Ukraine, regardless of what Western sanctions say.
This post explains what the Ukrainian sanctions list is, how it works, and what practical steps foreign businesses should take before entering into commercial relationships in Ukraine.
Ukraine’s Sanctions Regime: The Legal Basis
Ukraine’s sanctions framework is established by Law of Ukraine No. 1644-VII “On Sanctions”, adopted in 2014 and significantly expanded since the full-scale invasion in February 2022. The law authorises the application of restrictive measures against individuals and entities considered to pose a threat to national security, sovereignty, or territorial integrity.
Sanctions decisions are adopted by the National Security and Defence Council of Ukraine and enacted by presidential decree. They are legally binding within Ukraine.
What the Ukrainian Sanctions List Covers
The Ukrainian sanctions list includes:
- Russian and Belarusian individuals and entities — the largest category, covering state officials, military figures, companies involved in the defence sector, and businesses with significant state ties
- Individuals from other jurisdictions deemed to act against Ukrainian interests
- Ukrainian nationals and companies — in some cases, particularly those associated with collaboration or assets in occupied territories
The list is not static. It is updated regularly, and entries can be added, modified, or — less commonly — removed. Checking a counterparty once is not sufficient if you are engaged in an ongoing commercial relationship.
What Sanctions Measures Can Apply
Under Ukrainian law, a range of restrictive measures can be imposed, including:
- Asset freezes (blocking of funds and property within Ukrainian jurisdiction)
- Prohibition on transactions and commercial activity
- Cancellation or suspension of licences and permits
- Prohibition on capital movements and payments
- Prohibition on participation in privatisation or public procurement
The specific measures applicable to each listed person or entity are set out in the relevant presidential decree. Not all listed parties are subject to all measures — the scope matters.
Why This Is Relevant to Foreign Businesses
If you are a foreign company doing business in Ukraine — or planning to — Ukrainian sanctions create two categories of practical risk.
First: your Ukrainian counterparty may be listed. A Ukrainian or foreign company operating in Ukraine can be sanctioned by Ukraine. If your counterparty is subject to a transaction prohibition or asset freeze, any agreement you enter with them may be legally void or unenforceable within Ukrainian jurisdiction. Payments can be blocked. Contracts cannot be performed. The Ukrainian party has no legal ability to fulfil its obligations regardless of what the contract says.
Second: you may be dealing with an entity controlled by a listed person. Ukrainian sanctions can apply not only to the directly listed entity but to structures they control. A clean corporate name does not guarantee that the beneficial owner is not on the list.
For foreign businesses involved in trade, investment, or project financing involving Ukrainian counterparties, this is a compliance issue, not just a legal technicality.
How to Check the Ukrainian Sanctions List
The official source is the website of the National Security and Defence Council of Ukraine (rnbo.gov.ua), which publishes the current sanctions list and the relevant presidential decrees.
Additionally, the Ministry of Justice of Ukraine maintains related registers that can be cross-referenced.
In practice, a reliable sanctions check involves:
- Searching the RNBO database by name, EDRPOU code (for Ukrainian legal entities), or passport data (for individuals)
- Reviewing the specific presidential decree applicable to any match — to understand which measures apply
- Cross-referencing with the Unified State Register of Legal Entities to identify beneficial ownership and control structures
- For ongoing relationships, establishing a periodic re-check protocol — because the list changes
Searching by name alone is insufficient. Transliteration inconsistencies, use of initials, and variant spellings mean that a name-only search can miss a listed party. Identifier-based checks (EDRPOU, individual tax number) are more reliable.
Ukrainian Sanctions vs. Western Sanctions: Key Differences
Foreign businesses sometimes assume that if a counterparty is not on EU, US, or UK sanctions lists, they are clear. That assumption is wrong in both directions.
A party may be on the Ukrainian list but not on Western lists — in which case Western compliance tools will not flag them, but Ukrainian law still prohibits transacting with them inside Ukraine.
Conversely, a party may be on Western sanctions lists but not on the Ukrainian list — which creates a different set of compliance issues for the foreign business independent of Ukrainian law.
Running only one check gives you only half the picture. For any business activity touching Ukraine, both layers need to be reviewed.
Consequences of Non-Compliance
Transacting with a sanctioned party in Ukraine can result in:
- The transaction being declared void by a Ukrainian court
- Funds or assets being blocked by Ukrainian financial institutions
- Regulatory consequences for the Ukrainian counterparty that flow through to contract performance
- Reputational and compliance exposure for the foreign party in their home jurisdiction, depending on how their regulators treat transactions that breach a foreign sanctions regime
Ukrainian authorities have become significantly more active in enforcing sanctions compliance since 2022. This is not a theoretical risk.
Practical Recommendations
Before entering into any commercial relationship with a Ukrainian counterparty:
- Run a sanctions check against the RNBO list using identifiers, not just names
- Verify beneficial ownership — who ultimately controls the counterparty
- Review the specific decree if a match is found — the scope of restrictions matters
- Establish ongoing monitoring for long-term relationships
- Combine with general due diligence — sanctions status is one element of counterparty verification, not a substitute for broader checks
How I Can Help
I assist foreign businesses with counterparty due diligence in Ukraine, including sanctions screening, beneficial ownership analysis, and legal risk assessment. If you are entering a new commercial relationship in Ukraine or reviewing an existing one, I can help you establish whether your counterparty presents sanctions-related or other legal risks.
Contact me to discuss your situation.