The Verkhovna Rada adopted as a basis the draft law #12406 on criminalization of violation/intentional circumvention of sanctions
Main provisions:
- Establishment of criminal liability for violation/intentional circumvention of sanctions.
Penalties are a fine of UAH 425,000 to UAH 2 million or imprisonment for a term of 2 to 10 years, including confiscation of assets.
- Establishment of a value threshold – liability will be imposed for violations/ circumvention of sanctions committed in relation to assets worth more than UAH 151 thousand.
- Definition of sanctions circumvention: any actions aimed at concealing the assets of a sanctioned person.
What does the adoption of the draft law mean?
- The draft law becomes the basis for further work.
MPs, committees, and other subjects of legislative initiative can make their own amendments and clarifications. The deadline is 14 days.
We do not expect significant amendments.
- Political will – the Verkhovna Rada demonstrates support for the idea behind the draft law.
This indicates the likelihood of its adoption in general.
- Businesses should already prepare for changes in the legal framework and strengthen compliance procedures. To minimize risks, we recommend that you carefully review your counterparties, financial transactions and internal policies.
We will keep you updated on the progress of the draft law.
24/07/2025
