This Decree puts into effect the decision of the National Security and Defense Council of Ukraine regarding the application of personal special economic and other restrictive measures (sanctions). The document is an instrument for implementing state sanctions policy aimed at restricting the rights and assets of designated natural or legal persons. The decision of the National Security and Defense Council (NSDC), which is annexed to the Decree, contains specific lists of sanctioned entities and a schedule of the restrictions applied to them.
The structure of the Decree is standard for acts of this type: it consists of an operative part that puts the NSDC decision into effect, the designation of the official responsible for overseeing its execution (the Secretary of the NSDC), and a provision regarding its entry into force. The main provisions are based on the Law of Ukraine “On Sanctions,” which grants the NSDC the authority to initiate, and the President the authority to approve, the list of persons and types of restrictions. Compared to previous acts, this Decree is part of a continuous process of updating sanctions lists, which allows for an agile response to changes in the security situation.
Of the greatest importance for practical application are the provisions defining the list of specific persons to whom sanctions are applied and the types of these restrictions (e.g., blocking of assets, restriction of trade operations, suspension of the performance of financial obligations, etc.). For government agencies, banking institutions, and businesses, this Decree serves as direct guidance for the immediate cessation of any transactions with persons included in the sanctions list. It is important to note that the sanctions take effect from the moment of the Decree’s publication, which requires immediate verification of counterparties for compliance with the updated lists.
