This decision of the National Security and Defense Council, enacted by the Presidential Decree, serves as a mechanism for implementing state sanctions policy regarding specific legal entities. The document officially approves the list of companies to which personal special economic and other restrictive measures are applied. The execution of this decision is entrusted to the Cabinet of Ministers, the Security Service of Ukraine (SSU), and the National Bank of Ukraine, while the Ministry of Foreign Affairs is instructed to initiate reciprocal sanctions at the international level.
The structure of the act consists of an operative part, which defines the implementing subjects and procedural steps, and an annex containing the list of sanctioned legal entities. The decision is based on the provisions of the Law of Ukraine “On Sanctions”. Compared to previous similar acts, this document is a further stage in updating the sanctions lists, based on current proposals from the Security Service of Ukraine.
The most critical provisions for practical application are:
1. Legal enforceability: state authorities (in particular, the NBU) are obliged to ensure the implementation and monitoring of the effectiveness of the imposed restrictions.
2. International coordination: the Ministry of Foreign Affairs of Ukraine must officially appeal to partners (the EU, the USA, and other states) to synchronize sanctions pressure on the persons specified in the annex.
3. Personalization of restrictions: the sanctions apply to specific legal entities listed in the annex, which requires businesses and financial institutions to immediately verify counterparties for compliance with this list to avoid violations of the law.
