Sanctions Profile: Ukraine

At a glance

EU sanctions relating to Ukraine were first introduced in 2014, following Russia’s annexation of Crimea. The EU divides its sanctions imposed in relation to the Ukraine crisis into four separate regimes, three of which target Russia and its supporters and one of which chiefly targets ex-Ukrainian government officials, imposing asset freezes on people deemed responsible for the misappropriation of Ukrainian state funds or human rights violations (Council Regulation (EU) 208/2014 & Council Decision 2014/119/CFSP).

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OFAC extends general licences relating to Russian company GAZ Group

OFAC has extended two general licences related to the sanctioned Russian company GAZ Group until 31 March 2020. General Licence 13M and General Licence 15G provide exemptions for all otherwise prohibited transactions and activities that are ordinarily incident and necessary to divest or transfer debt, equity, or other holdings in GAZ Group to non-US persons or to maintain or wind-down …

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Ukraine and other countries align with EU’s extension of its Ukraine territorial integrity sanctions

Ukraine, Montenegro, Albania, and Norway have aligned their sanctions regimes with the EU’s decision on 12 September 2019 to extend its Ukraine territorial integrity sanctions until 15 March 2020 and amend the information for certain listed individuals and entities. The EU’s press release is here.

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ExxonMobil arguments in Rosneft US case

ExxonMobil has filed a memo in the Northern District of Texas District Court as part of its challenge to a $2m penalty imposed in 2017 for dealing with Igor Sechin, the designated CEO of Rosneft, who signed an agreement between Exxon and Rosneft. See post and post for case history. Case 3:17-cv-01930-B. ExxonMobil argues that the US Treasury’s interpretation of …

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2 more Ukraine misappropriation listings annulled

The EU  General Court has annulled the 2018 designations of Oleksandr Viktorovych Yanukovych (T-301/18, 24 September 2019) and Oleksandr Viktorovych Klymenko (C-11/18, 26 September 2019). The court followed the ECJ’s judgment in Azarov v Council (C-530/17, 19 December 2018, see post), where “it was in no way apparent from the statement of reasons for those [contested] acts that the Council …


Another Azarov judgment from EU court on proper approach to Ukraine misappropriation sanctions

The General Court has annulled the 2018 acts listing the former Ukrainian Prime Minister Mykola Yanovych Azarov on the EU’s Ukraine misappropriation sanctions. Case T-286/18 (11 September 2019). Mr Azarov’s 2015 listing was annulled by EU Court of Justice (C-530/17, see post), but not his 2016 (T-190/16, see post) or 2017 (T-215/15, see post) re-listings. The Court found that the …


Current Sanctions



Council Regulation (EU) 208/2014

Parent Regulation

Council Regulation (EU) 208/2014

Amended by:

Council Implementing Regulation (EU) 381/2014

Council Regulation (EU) 2015/138

Council Implementing Regulation (EU) 2015/357

Council Implementing Regulation (EU) 2015/869

Council Implementing Regulation (EU) 2015/1777

Council Implementing Regulation (EU) 2016/311

Council Implementing Regulation (EU) 2017/374

Council Implementing Regulation (EU) 2018/326

Council Implementing Regulation (EU) 2019/352

Council Implementing Regulation (EU) 2019/1403


Council Decision 2014/119/CFSP

Parent Decision

Council Decision 2014/119/CFSP

Amended by:

Council Implementing Decision 2014/216/CFSP

Council Decision (CFSP) 2015/143

Council Decision (CFSP) 2015/364

Council Decision (CFSP) 2015/876

Council Decision (CFSP) 2015/1781

Council Decision (CFSP) 2016/318

Council Decision (CFSP) 2017/381

Council Decision (CFSP) 2018/333

Council Decision (CFSP) 2019/354

Council Decision (CFSP) 2019/1405

The Ukraine (European Financial Sanctions) Regulations 2014 (SI 2014/507)