Speech by Head of ILI Tetiana Khutor at the conference “Ukrainian Business with Russian and Sanctioned Owners: Status, Challenges, Solutions”
The state must regulate the issue of the presence of Russian capital in the Ukrainian economy. This was stated by Head of the Institute of Legislative Ideas, Tetiana Khutor, during the third annual sanctions conference “Ukrainian Business with Russian and Sanctioned Owners: Status, Challenges, Solutions.”
“By the beginning of 2022, more than 18,000 Ukrainian companies had a share of Russian ownership. By the end of 2025, according to YouControl, about 5,800 such companies remained, excluding sole proprietors. Importantly, according to Opendatabot, from the start of the full-scale invasion until September 2025, 805 business entities managed to get rid of Russian owners despite legislative restrictions,” the expert said.
She noted that ILI experts analyzed 266 court decisions from 2023 and the second half of 2025 in which Cabinet of Ministers Resolution No. 187 was applied. This made it possible to systematize the main challenges in enforcement, including: its application to persons linked to Belarus, who are only subject to Resolution No. 18; inconsistencies in the temporal application of Resolution No. 187; confusion in aligning it with sanctions legislation; actual violations of the ban on changes in ownership structure; and limited practice of canceling such registrations.
“In addition, there are abuses of the moratorium to avoid fulfilling contractual obligations; limited exceptions are recorded that allow only certain companies to eliminate Russian ownership; and there are legal conflicts in interaction with state authorities, particularly in the tax sphere and in the return of seized funds,” added Tetiana Khutor.
The Head of ILI also explained how Ukraine’s international partners – the EU and its member states, the United States, and the United Kingdom – address such issues. According to her, these countries operate comprehensive models of economic security and countering the influence of aggressor states.
“In particular, their legislation provides for systematic investment screening and risk control, as well as sanctions regimes and special laws governing interaction with an enemy during wartime,” Tetiana Khutor emphasized.
Regarding solutions to the issue of Russian capital, the expert outlined several options: maintaining the imperfect existing regulation; lifting restrictions or expanding exceptions under Resolution No. 187; introducing a temporary mechanism to remove Russian ownership through lawful divestment or buyout of shares; or regulating relations with entities linked to the aggressor state through a new comprehensive law.
“We are now facing a choice. We can leave everything as it is, lift the restrictions, introduce targeted amendments, partially integrate this into the investment screening system, or move toward a comprehensive legislative solution governing interaction with the aggressor state,” concluded Tetiana Khutor.
