This NSDC decision, enacted by Presidential Decree No. 501/2026, officially approves the list of individuals and legal entities to which personal special economic and other restrictive measures (sanctions) are applied. The document is based on proposals by the Security Service of Ukraine and is aimed at implementing state sanctions policy. The execution and monitoring of these measures are vested in the Cabinet of Ministers, the Security Service of Ukraine, and the National Bank of Ukraine. Provision is also made for diplomatic efforts by the Ministry of Foreign Affairs to synchronize these sanctions with international partners.
The structure of the act consists of a resolution part and two annexes containing specific lists of sanctioned entities. The decision serves as an instrument for the implementation of the Law of Ukraine “On Sanctions,” where the NSDC acts as the body that initiates and approves the list of persons, and the President gives it legal force through a decree. Compared to previous similar decisions, this act serves as a targeted instrument that updates sanctions lists in accordance with current intelligence and security agency data.
The most important provisions for practical application are:
1. **Imperative Nature of Execution:** government authorities (in particular, the NBU and the Cabinet of Ministers) are obliged to ensure the immediate implementation of restrictions regarding the persons specified in the annexes.
2. **International Coordination:** the Ministry of Foreign Affairs of Ukraine must officially notify the EU and the USA of the imposition of these sanctions, which creates a foundation for expanding international pressure on the specified persons.
3. **Personalization:** sanctions are applied on a targeted basis to specific individuals and legal entities, which requires banking institutions and state registrars to immediately check their databases for compliance with these lists in order to block assets or suspend financial transactions.
