ILI Chair Tetiana Khutor comments to The Kyiv Independent on one of the most common sanction-evasion schemes and highlights the need to implement EU Directive 2024/1226

The Kyiv Independent has published an investigation into an attempt by Sergey Chemezov, a close ally of Vladimir Putin and a top figure in Russia’s defense sector, to lift sanctions from a $140 million superyacht linked to him.

In her comment for the publication, Tetiana Khutor, Chair of the Institute of Legislative Ideas (ILI), explained one of the most widespread mechanisms used to evade sanctions — artificially creating the illusion of a legitimate sale of an asset.

“These circumstances illustrate one of the most typical ways of evading sanctions. The fact that an agreement between private parties could have been back-dated indicates an attempt to create the illusion of a lawful transaction,” noted Tetiana Khutor.

Khutor also pointed out that Spanish law currently provides only administrative, not criminal, liability for sanction violations. This gap enables questionable transactions, allowing assets to be “sold” on paper without any real change of control.
Spain, like several other EU Member States, has yet to transpose Directive (EU) 2024/1226, which establishes criminal liability for sanction evasion — an issue repeatedly highlighted by ILI in its analytical work.

ILI emphasizes that a formal change of ownership does not eliminate the risk of a sanction violation if the asset effectively remains under the control of a designated person. Such cases demonstrate how crucial it is for governments and partners to strengthen sanction-enforcement mechanisms and harmonize their legal frameworks.

Read the full investigation in The Kyiv Independent.
More on sanction-enforcement practices and the implementation of Directive 2024/1226 — in ILI’s analytical materials.