Draft bill #12406 of January 14, 2025 

Sponsor: the President 

Status: sent for review to the Law Enforcement Committee 

Who is affected: individuals under sanctions, the National Securities and Stock Market Commission, the National Bank of Ukraine, and the Ministry of Justice 

Summary: 

  • a new article will be included in the Criminal Code to establish liability for crimes against the foundations of national security of Ukraine — sanctions, as well as intentional circumvention of sanctions. This article will stipulate that such crimes are considered grave 
  • a person will be criminally liable: 
    • if the violation involves assets or financial transactions worth over 100 non-taxable minimum incomes (1,700 UAH) 
    • for military and dual-use goods (i.e., those that can be used in both military and civilian spheres), this threshold will not apply. Such violations will be punishable regardless of value 
  • there will be no statute of limitations for such crimes 
  • additional penalties: 
    • prohibition on holding certain positions or engaging in specific activities 
    • penalties will apply not only to individuals but also to companies involved in the crime 
  • special confiscation of property for the committed crime will be introduced 
  • the following activities will be considered circumvention of sanctions: 
    • purchasing of blocked assets or other actions involving them, such as moving, converting, concealing, or masking them 
    • driving a company into bankruptcy or fictitious bankruptcy if it or its owner is sanctioned with asset blocking. 

What is right: the introduction of criminal liability for violating sanctions will contribute to stricter compliance with the law and reduce the risks that guilty individuals and legal entities avoid accountability.