Sanctions front: Ukraine has stepped up pressure on sanctioned individuals and companies, but some businesses are still operating

3 October 19:48

The Ministry of Justice of Ukraine has reported that since May 2022, 110 decisions of the National Security and Defense Council on the application and change of personal sanctions have been put into effect by presidential decrees, "Komersant Ukrainian" reports.

  • Sanctions have been imposed on about 17,800 people, including about 15,000 with asset freezes.
  • The Ministry of Justice has already filed 79 lawsuits to recover assets for the state.
  • Decisions have been made in 72 cases, including against 87 sanctioned persons.

These are primarily the assets of Russian oligarchs, MPs, collaborators and companies associated with the military-industrial complex of the Russian Federation.

How the mechanism works

The Ministry of Justice, together with other authorities:

  • identifies and traces the assets of persons under sanctions;
  • checks the grounds for their confiscation;
  • sends thousands of requests for verification (22,000 sent, 18,000 received).

Final decisions are made by the High Anti-Corruption Court and its Appeals Chamber.

Problems with the sanctions regime

Despite the bans, some businesses of sanctioned persons continue to operate.

  • According to OpenDataBot, there are 197 companies on the NSDC list, and some of them show strong financial results.
  • The Bureau of Economic Security found that the structures of Russian oligarch Konstantin Grigorishin supplied electricity to state institutions even after the imposition of sanctions.
  • In 2025 alone, 734 contracts were signed with his affiliated companies.

Hryhoryshyn is a citizen of Ukraine, Cyprus and Russia and has been under sanctions since early 2025.

After the full-scale invasion of Russia, Ukraine introduced a large-scale sanctions regime aimed at blocking Russian assets and businesses working for the war.

In 2022, for the first time, the procedure for confiscation of assets of sanctioned persons through the HACC was applied.

This is a unique model for international practice: most countries limit themselves to freezing assets, while Ukraine introduces a mechanism for their transfer to state ownership.

At the same time, international partners expect Kyiv to ensure transparency and credibility of the process, as sanctions have become one of the key instruments of economic pressure on Russia.

Марина Максенко
Editor

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