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On 15 March 2017, the President of Ukraine enacted the decision of the Ukrainian National Security and Defense Council (the “NSDC“) to impose sanctions on five Ukrainian banks with the capital of Russian state-owned banks: Sberbank PJSC; VS Bank PJSC; Prominvestbank PJSC; VTB Bank PJSC; and BM Bank PJSC (the “Sanctioned Banks“).1

The Sanctioned Banks are prohibited from transferring capital outside the territory of Ukraine in favour of any affiliated entities. Based on the current interpretation by the state authorities, this sanction includes prohibition against:

  • transferring any funds from the Sanctioned Banks to their affiliated entities;
  • transferring securities abroad from the securities accounts of the Sanctioned Banks; and
  • entering into any transactions with securities (or other financial instruments) of the Sanctioned Banks through securities traders.

The government and the National Bank of Ukraine are obliged to ensure implementation of the sanctions and take measures to prohibit companies with a state share from depositing funds with the Sanctioned Banks. Therefore, new regulations on implementation of the sanctions and detailed restrictions imposed by these sanctions should be approved within the next few weeks. The sanctions are imposed for the period of one year.

1The Decree of the President of Ukraine No. 63/2017 from 15 March 2017 enacting the NSDC’s Resolution dated 15 March 2017 “On Imposition of Personal Special Economic and Other Restrictive Measures (Sanctions)”.


Hanna Shtepa is a counsel in Baker McKenzie's Kyiv office.