What businesses should expect after sanctions policy reform: ILI Head Tetiana Khutor at an event for Ukraine’s compliance leaders

Ukraine needs to fundamentally revise its approach to sanctions policy, particularly the reporting system, which should become not a formality but a key tool for control and ensuring the effectiveness of sanctions. This was stated by the Head of the Institute of Legislative Ideas, Tetiana Khutor, during the National Compliance Forum 2026.

“Reporting is a mandatory element of sanctions policy reform in line with EU requirements. It will ensure the effectiveness of sanctions rules and contribute to the prevention, detection, and investigation of violations,” the expert said.

According to her, reporting obligations should include: suspicion of sanctions violations; identification of persons suspected of violations; detected but not yet blocked assets; changes in asset characteristics within two weeks prior to a person being added to a sanctions list; compliance with the “No Russia” requirement.

“It is also advisable to introduce annual reporting on blocked assets such as funds, economic resources (movable and immovable property), as well as economic operations (transport, legal, accounting and other services, export-import operations, investments, etc.). In addition, a self-reporting obligation should be introduced,” Tetiana Khutor added.

She noted that Ukraine’s current sanctions system also requires significant improvement in five other key areas: the application of sanctions, their appeal, licensing mechanisms, designation of a competent authority responsible for sanctions policy, and criminal liability for violations. In particular, draft law No. 12406 must be adopted.

“Parliament must adopt this document without risky provisions that would limit the application of sanctions to Ukrainian citizens, allow asset withdrawals through lawyers, or restrict liability only to intentional violations. At the same time, legislative amendments should be developed and administrative liability introduced as a more efficient and widely applicable enforcement tool,” the Head of ILI emphasized.

She stressed that these changes are important not only for the effectiveness of sanctions, but also as part of harmonizing Ukrainian legislation with EU standards.