A brief summary of the main things that businesses should know:
- Violation and circumvention are different offences
Now these are different parts of the Criminal Code article, not one offence
- Only intent
Criminal liability is only for intentional actions. Negligence is not punishable
- The threshold of liability has been raised
It was: UAH 151,400
It became: UAH 454,200
- Exceptions for basic expenses
Sanctions will not apply to payment of court fees, utilities, etc.
It is also allowed to conclude an agreement with a lawyer and pay a fee (the obligation to develop a procedure for payment of fees is assigned to the Cabinet of Ministers).
- Protection for financial institutions
In addition, banks, insurers, and credit unions will no longer be subject to liquidation in case of violation/ circumvention of sanctions.
- What is considered to be a circumvention?
The list of action qualified as sanctions circumvention was amended by concealment of information about assets that should be frozen.
- The range of voidable transactions has been narrowed
Now, only those transactions concluded in violation of the Law on Sanctions and resulting in a change of ownership of assets may be recognised as voidable
Edits provided by VB Partners were also taken into account.

