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Improving sanctions policy

This project aims to strengthen Ukraine's sanctions policy system by addressing critical problems identified in its current framework and developing an additional funding source for Ukraine.

The project focuses on developing a framework to increase predictability and transparency, as well as to prevent potential abuse of sanctions by establishing clear grounds for their application, improving appeal procedures, and developing a unified institutional structure.

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Transposition of EU Directive 2024/1226 by EU Member States: Definition of Criminal Offences and Penalties for Violations of Union Restrictive Measures

This analytical study examines the transposition of EU Directive 2024/1226 on the definition of criminal offences and penalties for violations of Union restrictive measures by EU Member States and offers recommendations for improving Ukrainian legislation on the criminalisation of violations and circumvention of sanctions in the view of European integration.

Sanction policy

Authors:

Rubashchenko Mykola, Andriy Klymosyuk, Oksana Huzii, Tetiana Khutor

23 Sept. 2025

Analysis of the practice of the High Anti-Corruption Court regarding the application of sanctions in the form of confiscation of assets to the state budget for 2022-2025

This study presents an analysis of 56 cases of the High Anti-Corruption Court in which the sanction of asset forfeiture to the state was applied

Anti-corruption policy

Authors:

Taras Riabchenko, Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh

19 June 2025

White Paper: The Future of European Leadership in the Economic Deterrence of Aggression

Global security threats are growing in scale and complexity – reaching deep into finance, trade, and critical technologies. That is why economic measures, such as sanctions and export controls, have become not only instruments of political pressure, but also core components of modern security policy

Sanction policy

27 May 2025

Reinforcing the Legal Framework for Seizing Frozen Russian Assets

Policy paper

Reparations in Ukraine

Authors:

Oksana Huzii, Tetiana Khutor

25 May 2025

Explanatory notes to the Draft Law on Amendments to the Criminal Code of Ukraine, the Criminal Procedure Code of Ukraine and the Law of Ukraine ‘On Sanctions’ regarding the establishment of liability for violations of special economic and other restrictive measures (sanctions) No. 12406

The criminalisation of violations of restrictive measures should be carried out with mandatory harmonisation, as far as possible without fundamental changes to existing legal institutions, with EU Directive 2024/1226 on the definition of criminal offences and sanctions for violations of restrictive measures of the Union of 24 April 2024

Sanction policy

13 May 2025

Best approaches to criminal prosecution of sanctions violations: Ukrainian and international context

The need to criminalise the violation and circumvention of sanctions in Ukraine is a long-standing issue. At the same time, our foreign partners are already effectively prosecuting sanctions violators and those who facilitate sanctions evasion through criminal law.

Sanction policy

Authors:

Andriy Klymosyuk, Rubashchenko Mykola

9 Jan. 2025

Amicus Curiae opinion

By the Think Tank «Institute of Legislative Ideas» on the constitutional complaint by AEROC Investment Deutschland GmbH

Sanction policy

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh

30 Dec. 2024

Moratorium on the fulfillment of obligations to Russia and persons associated with the aggressor state: analysis of court practice

Russia has committed an act of armed aggression against Ukraine. However, Russia's influence on our country has deep roots. In the economic sphere, it stems from the legacy of the shared economic past of the Soviet Union and Ukraine's ambiguous multi-vector policy in the early years after regaining independence in 1991

Authors:

Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko, Svitlana Hordiienko, Artem Panchenko

26 Dec. 2024

Civil confiscation and asset forfeiture for violation of sanctions. Steps to be taken by Ukraine

The research analyzes the best practices of civil asset forfeiture and confiscation in criminal proceedings, as well as ways to improve Ukrainian legislation, in particular in the context of asset recovery for violation of sanctions imposed on Russia.

Sanction policy

Authors:

Andriy Klymosyuk, Rubashchenko Mykola, Tetiana Khutor, Oksana Huzii

27 Nov. 2024

Establishment of actual control over the asset and protection of the rights of third parties in the practice of applying the sanction of asset recovery to the state revenue.

The study focuses on the sanction provided for in paragraph 1-1 of Part 1 of Article 4 of the Law of Ukraine “On Sanctions”, namely, the recovery of assets belonging to an individual or legal entity for the benefit of the state.

Anti-corruption policy

Authors:

Tetiana Khutor, Bohdan Karnaukh

29 May 2024

How sanctions are enforced in the United States: a multi-level mechanism of responsibility

The research focuses on the mechanism of enforcement of sanctions restrictions in the United States and the two levels of liability for circumventing sanctions - civil and criminal. This mechanism has demonstrated its effectiveness and can serve as an example for both Ukraine and other Western democracies interested in the strength of sanctions policy.

Sanction policy

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko

30 April 2024

EU Directive 2024/1226 on the criminalization of sanctions violations: Overview and recommendations for Ukraine

The study analyzes the European Union Directive 2024/1226 on the definition of criminal offenses and penalties for circumvention of sanctions and the main principles of criminalization of non-compliance with restrictive measures in Ukraine.

Sanction policy

Authors:

Andriy Klymosyuk, Rubashchenko Mykola

30 April 2024

Analysis of the impact of sanctions on the operations of extractive companies

A study on blocked subsoil enterprises with detailed performance indicators

Anti-corruption policy

Authors:

Andriy Klymosyuk, Tetiana Khutor, Taras Riabchenko, Svitlana Hordiienko, Artem Panchenko

15 April 2024

Analysis of the practice of the High Anti-Corruption Court on the application of sanctions in the form of asset forfeiture to the state for 2022-2023

This study presents an analysis of 32 cases of the High Anti-Corruption Court in which the sanction of asset forfeiture was applied

Anti-corruption policy

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko

5 Jan. 2024

Overview of the current regulation of liability for sanctions evasion: state of play and prospects

The research paper describes the state of play and main trends in Europe and the United States with regard to evasion of sanctions imposed as a result of Russian aggression and criminalisation of such activities.

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko

7 Sept. 2023

Standards of trial in absentia and the case law of the HACC concerning collection of sanctioned persons assets into state income (summary)

The study addresses the applicability of the standards of trial in absentia (in the absence of the accused) to cases concerning the application of a sanction in the form of asset forfeiture under Article 5-1 of the Law of Ukraine ‘On Sanctions’

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko

7 July 2023

Analysis of the High anti-corruption courts law concerning the application of sanction on the form of asset forfeiture

This study presents an analysis of 15 decisions of the High Anti-Corruption Court (HACC) and 2 decisions of the HACC Appeals Chamber imposing a sanction in the form of asset forfeiture

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko

24 March 2023

Analysis of the High Anti-Corruption Court’s case law concerning the application of sanction in the form of asset forfeiture

This study presents an analysis of 15 decisions of the High Anti-Corruption Court (HACC) and 2 decisions of the HACC Appeals Chamber imposing a sanction in the form of asset forfeiture

Authors:

Andriy Klymosyuk, Tetiana Khutor, Bohdan Karnaukh, Taras Riabchenko

24 March 2023

Brief overview of HACCU decisions on confiscation of assets of Russian rectors

Authors:

Tetiana Khutor, Taras Riabchenko

14 Dec. 2022

Major concerns on the Ukrainian mechanism of asset forfeiture as a sanction

This Brief provides an overview of the main substantive and procedural problems of the Ukrainian legislative framework of sanctions in the form of asset forfeiture together with the first court case on application of this sanction. This analysis is based on the standards of non-conviction based forfeiture and the ECHR case-law.

Sanction policy

Authors:

Andriy Klymosyuk, Tetiana Khutor, Taras Riabchenko

15 Nov. 2022

Forfeiture of assets belonging to persons responsible for Russia’s aggression against Ukraine

ANALYSIS AND RECOMMENDATIONS FOR IMPROVEMENT OF UKRAINIAN LEGISLATION AND PRACTICE OF ITS IMPLEMENTATION

Authors:

Andriy Klymosyuk, Tetiana Khutor, Taras Riabchenko

3 Nov. 2022

Sanctioned confiscation of private assets in Ukraine: recommendations for application in the light of ECHR practice

This document is a continuation of the Centre's work in this area and aims to help the authorities responsible for preparing materials, claims and decisions on the recovery of such assets to build future practice in accordance with current international approaches to asset confiscation and minimise the risks of further successful appeals against such procedures.

Authors:

Andriy Klymosyuk, Tetiana Khutor, Taras Riabchenko

18 Aug. 2022