A brief summary of the main things that businesses should know:

  1. Violation and circumvention are different offences

Now these are different parts of the Criminal Code article, not one offence

  1. Only intent

Criminal liability is only for intentional actions. Negligence is not punishable

  1. The threshold of liability has been raised

It was: UAH 151,400

It became: UAH 454,200

  1. 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).

  1. 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.

  1. 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.

  1. 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.

24/07/2025
Логотип - VB Partners