The State Sanctions Register is launched

In July 2023, the Law of Ukraine “On Amendments to Certain Legislative Acts of Ukraine on Imposition of Sanctions” came into effect. The Law provides for the creation of the State Sanctions Register (the “Register”).

Decree of the President of Ukraine No. 36/2024 dated 29 January 2024 enacted the Decision of the National Security and Defense Council of Ukraine “On Approval of the Regulation on the State Sanctions Register” (the “Regulation”), which enabled the launch of the Register.

Below is a brief overview of the Register and its functionality.

• The Register consolidates information on persons subject to sanctions imposed on the grounds of:
  1. Decisions of the National Security and Defense Council of Ukraine, enacted by decrees of the President of Ukraine, and in cases provided for by the Law of Ukraine "On Sanctions", approved by resolutions of the Verkhovna Rada of Ukraine.
  2. Court decisions on the imposition of sanctions provided for in para. 1-1 of Part 1 of Article 4 of the Law of Ukraine “On Sanctions” – seizure by the state of assets belonging to an individual or legal entity, as well as assets in respect of which such an individual or legal entity may directly or indirectly (through other individuals or legal entities) perform actions identical in content to the exercise of the right to dispose of them.
• The Regulation stipulates that the Register will be available both in Ukrainian and in English. However, only the Register’s interface is available in English, while other information can be viewed only in Ukrainian language (for example, additional information about sanctioned persons, such as employment, place of registration, etc.).
• Users can access the Register free of charge and obtain an extract in electronic form.
• It should be noted that the search in the Register is performed only by full matching of the search fields. Therefore, it is advised to pay attention to possible differences in spelling and transliteration of surnames and names, as well as to errors in the search fields.
• The Register also contains information on the duration, modification, and cancellation of sanctions.
• The Register can be accessed via APIs for the integration with existing IT solutions.
• We draw your attention to a notice on the Registry’s website about the possible cases of incorrect data display in the initial stages of its operation due to the technical validation of data in large volumes.
  
  

We believe that the Register will be a useful tool for checking on counterparties/clients. However, we see that there are still areas that can be improved to make the use of the Register more efficient.

How Deloitte experts can help you

Our team offers the following services:

• Review and assessment of risks associated with working with clients/counterparties, as well as development of methodology for risk exposure assessment.
• Development of internal documents related to sanctions policies, due diligence of counterparties in accordance with legal requirements and group standards.
• Incorporation of legal requirements in internal documents on sanctions implementation.
• Ongoing consultations on sanctions implementation/screening, compliance with sanctions legislation.
  
  

If you have any questions or need advice, please contact us.

We will continue to monitor key legislative developments and share useful information with you.

Subscribe to our Telegram channel "Deloitte Ukraine Voices" to stay tuned on the latest firsthand news, articles, podcasts, and other materials. Hear the voices of our experts!

Return to the previous page: Tax & Legal Alerts 2023