Criminalization of Sanctions: What Will Change for Businesses and How to Avoid the Risks
On May 7, the online intensive “Sanction Force – 2025: No Room for Error” took place, jointly organized by the educational project FinMon School, the Ukrainian Network of Integrity and Compliance (UNIC), and the VKURSI data platform for counterparty verification. The event provided a strong platform to discuss the implications of Draft Law No. 12406, which proposes criminal liability for violations of the sanctions regime.
The key highlight of the event was a discussion-interview between Olga Shenk, Partner at CMS Cameron McKenna Ukraine and UNIC expert, and Tetiana Khutor, Head of the Institute of Legislative Ideas and one of the initiators and co-authors of the draft law.
💬 During the conversation, Tetiana Khutor addressed several crucial issues:
- International standards and best practices that guided the development of Draft Law No. 12406. She emphasized that the initiative is a critical step toward aligning Ukrainian legislation with EU and U.S. requirements.
- Circumvention vs. violation of sanctions — a clear distinction between these legal concepts and who bears responsibility for each.
- How violations will be detected and proven. The discussion covered proposed mechanisms ranging from financial monitoring to the role of law enforcement.
- Sanctions compliance as a prevention tool. Tetiana Khutor underscored the importance of implementing internal procedures to help businesses avoid unintentional breaches, especially when dealing with international partners.
📌 The intensive gathered over 250 participants — including business representatives, public sector professionals, and compliance officers — who not only received practical guidance but also engaged in dialogue about upcoming changes in the legal regulation of sanctions policy.