The procedure for lifting sanctions must be transparent and effective, which is a sign of mature institutional capacity.
Since the start of the war, Ukraine has actively used sanctions as a tool of economic and political pressure. Currently, there are 21,000 individuals and legal entities on the sanctions lists. Although in many cases this is a justified step, especially in wartime, sanctions have not always been reasonable.
Before and after the start of the full-scale invasion, Ukraine acted quickly, sometimes even too quickly. People and companies were subject to restrictions not because of real ties to the aggressor state, but because of outdated publications on the Internet or unverified assumptions. The legal grounds for sanctions were often replaced by information noise.
Sanctions have gradually replaced other legal mechanisms: criminal prosecution and lawsuits regarding assets nationalization. In other words, they have evolved from a tool for protecting national security into a mechanism that poses risks to reputation, the investment climate and the very idea of the rule of law.
Sanctions without evidence are not about justice, but about arbitrariness. Until last weekend, the state did not acknowledge its mistakes in its sanctions policy. In the ten years that sanctions have been in place, there have been only a few cases of their cancellation.
The case of a French citizen became revolutionary when the Supreme Court sided with the sanctioned person and the President of Ukraine admitted his mistake. What happened?
In February 2023, on the initiative of the National Bank of Ukraine, the President imposed sanctions on a banker for his employment in the governing body of a Russian bank. In fact, the stated grounds did not exist: the person had ceased all cooperation with this bank back in October 2020.
We began comprehensive work to lift the sanctions and restore the person’s reputation at the administrative and judicial levels. Evidence of the groundlessness of the sanctions was provided to the National Bank, the National Security and Defense Council, the President and other state bodies. The French Embassy in Ukraine was also involved, which emphasized the reputational significance of the case at the international level.
After two years of struggle, the sanctions were lifted. In February, the Supreme Court ruled that the presidential decree imposing sanctions was unlawful. This was the first court decision to lift sanctions imposed by the current President. Realizing that the appeal was futile, the president filed an appeal, so the decision did not take effect.
On 4 October 2025, without waiting for the results of the appeal, the president corrected the mistake and finally lifted the sanctions by his decree. In fact, he complied with the requirements of the European Court of Human Rights, which emphasizes the state’s obligation to verify the reality and validity of the grounds for sanctions.
The significance of this case cannot be overestimated. This precedent became the basis for a reassessment of the entire sanctions list. Thus, on 10 October 2025, the President lifted restrictive measures against another individual on the same list.
The state’s acknowledgement of its mistakes is a positive sign. The business climate needs predictability. Sanctions without clear reasoning, the lack of an effective procedure for reviewing and lifting them, send a signal to investors about legal uncertainty in Ukraine. On the other hand, lifting erroneous sanctions demonstrates to businesses that the state’s legal system is capable of functioning even in politically sensitive matters.
We hope that this case will become a catalyst for change in the area of sanctions: the grounds for imposing sanctions will be carefully examined, and the state will not only impose restrictions but also legally rectify its own mistakes.
The procedure for lifting sanctions must be transparent and effective so that a person who has been unjustifiably sanctioned does not have to wait two years to restore his/her rights and reputation. This is a sign of mature institutional capacity.
Partner Denys Shkarovsky for Ekonomichna Pravda
