ILI Project Manager Andrii Klymosiuk explained why the absence of reporting makes sanctions “half-blind”
Ukraine’s sanctions policy still contains critical gaps, in particular the absence of a mandatory reporting mechanism. This is stated in an article by ILI Project Manager Andrii Klymosiuk for Business Censor.
“On April 1, 2026, the Cabinet of Ministers approved the National Programme for the Adaptation of Legislation to EU law (the EU acquis), which provides for the implementation of European approaches to sanctions by the end of 2027. At the same time, Ukraine currently lacks a system that would oblige businesses, financial institutions, or sanctioned individuals to report assets, transactions, or risks of sanctions evasion. Some elements of reporting exist, but they are fragmented and do not form a coherent system,” the expert noted.
According to him, the absence of reporting makes sanctions “half-blind.” The state does not have complete information about frozen assets, their movement, or attempts to circumvent restrictions. In the EU, the United States, and the United Kingdom, reporting is a mandatory component of sanctions regimes and serves as the foundation for investigations and enforcement.
“The problem has several dimensions. From a security perspective, the state cannot verify whether all assets of sanctioned individuals are blocked or whether they are being moved through third parties. In enforcement, the lack of reports makes it more difficult to detect and prove violations. From an economic perspective, businesses face uncertainty: companies do not understand whether they must report links to sanctioned individuals or how exactly to do so,” explained Andrii Klymosiuk.
The ILI expert emphasized that introducing sanctions reporting is a direct obligation of Ukraine within the framework of European integration. The European sanctions model is based not only on a list of restrictions but also on a system for monitoring compliance, where reporting is a key element.
“Without a fully functioning reporting mechanism, it is impossible to fulfill EU integration obligations. All these dimensions indicate that reporting is not an optional element of sanctions policy,” Andrii Klymosiuk stressed.
Among the necessary steps, he names: amending the Law “On Sanctions” to establish a reporting obligation; expanding the range of reporting entities (including non-financial professions); introducing self-reporting for sanctioned individuals; and creating a unified digital tool for submitting reports. In addition, it is proposed to establish liability for violations of reporting requirements – from administrative liability for minor breaches to criminal liability for intentional concealment of information or submission of false data.
“As long as there is no mandatory sanctions reporting in Ukraine, sanctioned individuals can hide assets without any consequences. Introducing this tool is at the same time a matter of effectiveness, security, and European integration. The National Programme for the Adaptation of Ukrainian legislation to EU law (the EU acquis) provides both the framework and the deadline for this,” the ILI expert concluded.