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On 30 October 2021, the president of Ukraine enacted four decisions of the National Security and Defense Council of Ukraine (NSDC) imposing personal special economic and other restrictive measures (sanctions) (“Decisions”). The Decisions impose extensive sanctions restrictions, including, among others, asset freezes, restriction on the exit of capital from Ukraine, a ban on trade operations and the transit of resources, flights and transportation within the territory of Ukraine, and the suspension of the performance of economic and financial obligations, etc., upon legal entities and individuals involved in the following: 

  • The shipbuilding industry (PO More Shipyard (Crimea) and PJS Sevastopol company Era (Ukraine))
  • Trade operations of Ukrainian airway companies with Iran (Camus Air, UM Air and Khors Air)
  • The entry of Russian supermarket chain Mere into the Ukrainian market (Alexander Scheglov, Andrei Schneider, Ivan Schneider, Sergey Schneider and Andrey Veykulaynen; related companies Globaltreyd LLC, Krymprodukt LLC, Gradoplan-Kryim LLC, NSKTreyd LLC, Renessansmed LLC and Torgservis 324 LLC; and related trademarks MERE, Svetofor, Svitofor and Mayak)
  • Cyberattacks (including sanctions against Group IB companies, Trust Ltd., etc.)
  • Domain registration (reg.ru)
  • Elections to the Russian State Duma and human rights violations in the temporarily occupied territory of Crimea (including members of election commissions, law enforcement officials, Simferopol’s Detention Center No. 1, etc.)

The full lists of the legal entities and individuals subject to sanctions are set forth in the annexes to the Decisions.
 
On 28 October 2021, the president of Ukraine enacted the NSDC decision imposing personal special economic and other restrictive measures (sanctions) in line with the United Nations Security Council resolutions on the Republic of Yemen (“Decision”).
 
The Decision introduced a ban on the entry into and transit through the territory of Ukraine, asset freezes and an arms embargo against the following individuals: 

  • Abd Al-Khaliq Al-Houthi, Al-Houthi commander
  • Abdullah Yahya Al Hakim, one of the Al-Houthi leaders
  • Ali Abdullah Saleh, former president of the Republic of Yemen and General People’s Congress leader
  • Abdulmalik Al-Houthi, Yemeni Hussite leader
  • Ahmed Ali Abdullah Saleh, former ambassador and brigadier general
  • Sultan Saleh Aida Aida Zabin, director of the Criminal Investigation Department of Sanaa

Any counterparty dealing with entities or individuals on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.


1 Presidential Decree No. 556/2021 dated 30 October 2021 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),’” effective from 4 November 2021; Presidential Decree No. 557/2021 dated 30 October 2021 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),’” which will become effective upon the official publication of the president’s decree enacting such decision and the full text of the decision; Presidential Decree No. 558/2021 dated 30 October 2021 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),’” effective from 4 November 2021; Presidential Decree No. 559/2021 dated 30 October 2021 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions),’” effective from 4 November 2021.

2 Presidential Decree No. 555/2021 dated 28 October 2021 “On the Decision of the National Security and Defense Council dated 15 October 2021 ‘On Imposition of Personal Special Economic and other Restrictive Measures (Sanctions) According to the Resolutions of the UN Security Council,’” effective from 30 October 2021

Author

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

Author

Hanna Smyrnova is an Associate in Baker McKenzie Kyiv office.

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