On 7 August 2025, the government submitted a bill to parliament which, despite its stated aim of increasing the transparency and accessibility of registration processes, poses a threat to Ukraine's sanctions policy

The document allows for the state registration of persons subject to sanctions on the basis of court decisions.

This opens up the possibility of unfreezing frozen assets or corporate rights, effectively despite the existing sanctions restrictions.

This approach:

• contradicts European practices, where special permission from a competent authority is required to unfreeze assets in accordance with court decisions;
• undermines the harmonisation of Ukrainian legislation with EU law;
• creates risks for circumventing sanctions and withdrawing assets.
• IZI, as co-author of draft law No. 12406 on the criminalisation of sanctions violations, emphasises that Ukraine needs a mechanism for authorising actions prohibited by sanctions, rather than exceptions that open the door to abuse.

This is an international standard that will make sanctions policy more transparent and flexible, as well as minimise the risk of human rights violations.

📄 For a detailed analysis, see the analytical note at link.