On 19 March 2024, the Ukrainian Government decided to close a sanctions-related database maintained by the National Agency on Corruption Prevention (“NACP”).
Back in early 2022, the NACP had initiated the “War & Sanction Portal”. This online portal featured sections like “International Sponsors of War”, “Candidates for Sanctions” and other lists covering a range of areas. It also included lists of individuals and companies that were being sanctioned in Ukraine and its partner countries (“Database”).
The Database was set up as part of a wider effort led by the Yermak-McFaul Sanctions Group to enhance sanctions and put pressure on Russia to cease its war against Ukraine. The NACP analysed publicly available information about companies and individuals and listed the ones, who financially supported the Russian government through business or other means. Although inclusion on the lists did not lead to immediate legal consequences, it could cause reputational damage.
The Ukrainian Government stated that there was no regulatory framework for the existence of the Database. In addition, the Ukrainian Government sees no need in maintaining the Database, as all official information on the imposed sanctions is included in the State Register of Sanctions (link).
Information on persons from the “International Sponsors of War” list will be transferred to the Interagency Working Group on the Implementation of the State Sanctions Policy to process and assess the existence of grounds for imposing sanctions on the persons.
As a result, the State Register of Sanctions will from now on serve as the sole official database of sanctioned entities in Ukraine.
By Yuriy Nechayev, Partner, Avellum
