State Registry of Sanctions

04 April 2023
State Registry of Sanctions
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Draft bill #8392 of January 27, 2023 

Status: adopted in the first reading. The draft bill will still be amended 

Who is affected: natural persons and legal entities under sanctions, the National Security and Defense Council, the President, the Cabinet, businesses, Ukrainian citizens, and foreigners 

Summary of the bill: 

  • the State Registry of Sanctions will be established to collect, store, protect, maintain, and provide information about all natural persons and legal entities under sanctions. The data from this registry will be open and publicly accessible 
  • the registry will be maintained in Ukrainian and English. Information will be available in formats accessible for automated collection, processing, and downloading 
  • the registry will include: 
    • reasons why the sanctions were imposed, modified, and lifted 
    • list of the applied sanctions 
    • government bodies responsible for the implementation of the National Security and Defense Council’s decisions imposing sanctions 
    • list of persons under sanctions 
    • information about the agents proposing to impose, modify, or lift sanctions 
  • it will be allowed to submit appeals challenging the imposition of sanctions, in particular, confiscation of assets, only while martial law is declared 
  • the deadline for the High Anti-Corruption Court to consider cases regarding the imposition of sanctions will be increased from 10 to 30 days. The absence of plaintiffs, who have been properly informed about the date, time, and place of the hearing, will not stop the court from working 
  • decisions by the High Anti-Corruption Court on the imposition of sanctions, in particular, confiscation of assets, will be sent to the Cabinet of Ministers on the day they become legally binding. 

What is right: information about sanctions will be more available to the public and convenient to use. If the bill is adopted, it will be transparent who requested the imposition of sanctions and the reasons why sanctions were imposed against natural persons and legal entities. 

What is wrong: persons under sanctions, in particular, those whose assets were confiscated, will be unable to challenge President’s decisions imposing these sanctions in court. The draft bill provisions that such appeals can be submitted only while martial law is declared. The President, however, can impose sanctions both during wartime and peacetime. 

Alternative solution: make it possible to challenge the President’s decisions imposing sanctions, in particular, confiscation of assets, during peacetime.