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.
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
27 May 2025
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25 May 2025
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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
13 May 2025
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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.
9 Jan. 2025
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Amicus Curiae opinion
By the Think Tank «Institute of Legislative Ideas» on the constitutional complaint by AEROC Investment Deutschland GmbH
30 Dec. 2024
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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
26 Dec. 2024
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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.
27 Nov. 2024
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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.
29 May 2024
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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.
30 April 2024
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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.
30 April 2024
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Analysis of the impact of sanctions on the operations of extractive companies
A study on blocked subsoil enterprises with detailed performance indicators
15 April 2024
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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
5 Jan. 2024
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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.
7 Sept. 2023
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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’
7 July 2023
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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
24 March 2023
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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
24 March 2023
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Brief overview of HACCU decisions on confiscation of assets of Russian rectors
Brief overview of HACCU decisions on confiscation of assets of Russian rectors
14 Dec. 2022
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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.
15 Nov. 2022
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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
3 Nov. 2022
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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.
18 Aug. 2022
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Sanctioned confiscation of private assets. Essence and implementation
Analysis and recommendations for improving Ukrainian legislation and its implementation
17 Aug. 2022
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