On 27 June 2025, the President of Ukraine signed decree No. 422/2025 enacting the decision of the National Security and Defence Council of Ukraine (“NSDC”) “On Synchronisation of Sanctions Pressure of Ukraine, the European Union and Other Members of the Group of Seven on the Russian Federation and Related Entities”, dated the same day (“Decision”).
The Decision envisages:
- Full implementation of sanctions imposed by international partners: The Cabinet of Ministers of Ukraine, the Security Service of Ukraine and the National Bank of Ukraine must ensure full implementation of all sanctions imposed by international partners in Ukraine.
- Accelerated synchronisation: Restrictive measures approved by international partners must be submitted to the NSDC for consideration and approval within 15 days after the decision comes into force in the respective country or bloc. This will ensure the rapid alignment of sanctions lists.
- Mutual coordination of Ukrainian sanctions: The Cabinet of Ministers of Ukraine, the Security Service of Ukraine, the Foreign Intelligence Service of Ukraine, and the Prosecutor General’s Office must appeal to the EU, the USA, and other states regarding the implementation of sanctions applied by Ukraine in connection with the armed aggression of the russian federation.
For companies doing business in Ukraine, this means a simplification of sanctions compliance: sanctions imposed by the EU, the USA, and other international partners will be officially incorporated into the Ukrainian legal system and will be available for screening through the State Sanctions Register. The Decision should reduce the need for parallel monitoring of foreign sanctions lists, allowing businesses to focus on complying with national legal requirements.
The Decision is available in Ukrainian via the link.
On 1 July 2025, the President of Ukraine already enacted 3 NSDC decisions, thereby synchronising Ukraine’s sanctions with the EU’s 9th to 14th sanctions packages.
Additional notes
This legal alert is issued to inform AVELLUM clients and other interested parties of legal developments that may affect or otherwise be of interest to them. The information above does not constitute legal or other advice and should not be regarded as a substitute for specific advice in individual cases.
For further information on the Decision and other issues related to the imposition of sanctions in Ukraine, please contact partner Yuriy Nechayev.
