Andriy Klymosyuk
project manager
klymosyuk@izi.institute
2015 - Master of Laws - Yaroslav Mudryi National Law University
2019 - PhD in Law - Yaroslav Mudryi National Law University
2024 - Master of Public Administration - "University of educational management" National Academy of Educational Sciences of Ukraine
Since September 2024, he has been the Head of the Integrity Council at the State Service of Ukraine for Transport Safety.
He implements projects in the following areas: corruption risk assessment in the field of road transport; criminalization of sanctions violations and circumvention, criminal and civil asset confiscation, management of sanctioned assets, and ensuring access to the Register of Losses for victims of Russian aggression.
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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.
23 Sept. 2025
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Proposals for the Improvement of Draft Law No. 12406
On July 9, the Committee of the Verkhovna Rada of Ukraine on Law Enforcement approved the version of Draft Law No. 12406 proposed for the second reading. The Analytical Center 'Institute of Legislative Ideas' analyzed the comparative table with the Committee's supported amendments.
28 Aug. 2025
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Analytical note on draft law №13606 in the context of the possibility of performing registration actions in relation to persons subject to sanctions
On August 7, 2025, the Cabinet of Ministers of Ukraine initiated the registration of a draft law “On Amendments to Certain Legislative Acts of Ukraine in the Field of State Registration to Ensure Public Legal Interest” (No. 13606).
11 Aug. 2025
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Lessons from the July crisis – how to preserve the independence of institutions under pressure from war, politics, and populism
Legal and political analysis of draft laws №12414 and №13533 and conclusions for the future
8 Aug. 2025
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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
19 June 2025
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Compensation for housing destroyed or damaged by the Russian–Ukrainian war
The study analyses international norms, experiences of post-conflict countries, domestic legislation, and case law along the path of a victim.
6 June 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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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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What should the International Register of Damage take into account when designing procedures for submitting and reviewing applications concerning destroyed or damaged housing?
This document outlines the major challenges faced by owners of damaged or destroyed real estate when documenting losses with a view to obtaining compensation.
14 Sept. 2024
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Assessment, management and implementation of assets in ARMA. How to improve the efficiency and functionality of the agency
The publication was published by the Institute of Legislative Ideas with the support of ICAP Ednannia within the framework of the Sectoral Support Initiative for Ukrainian Civil Society, implemented by ICAR Ednannia in consortium with the Ukrainian Center for Independent Political Research (UCIPR) and the Center for Democracy and Rule of Law (CEDEM).
13 Sept. 2024
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Submitting a claim for damages to the Register of Damages for Ukraine: practical advice to victims
The Manual, developed on the basis of official documents of the Registry, is intended to help victims receive clear and concise information on the possibility of filing a relevant application and the steps to be taken.
12 Sept. 2024
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An effective and transparent procedure for accreditation of legal education programs as a prerequisite for the quality of legal education
Report on the results of the analysis of the practice of accreditation of educational programs
10 June 2024
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Policy Brief: Effective and Transparent Accreditation Procedure for Law Degree Programmes as a Prerequisite for the Quality of Legal Education
This policy brief presents the results of an independent study of accreditation by the National Agency for Higher Education Quality Assurance of study programmes in the specialities 081 ‘Law’, 293 ‘International Law’ and 262 ‘Law Enforcement’ for 2020-2022.
10 June 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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Policy Brief: Raid inspections of passenger road transport: a tool for detecting violators or an opportunity for abuse?
This policy brief presents the results of an independent study of the mechanism of conducting roadside inspections of passenger road transport as a form of state supervision carried out by the State Service of Ukraine for Transport Safety.
26 March 2024
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Raid inspections of passenger road transport: a tool for identifying violators or an opportunity for abuse?
The study uses a unique COI methodology based on a combination of regulatory expertise and analysis of the implementation of identified shortcomings and corruption risks in practice.
26 March 2024
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Compensation for war-related moral damage: Ukrainian and international practice
This paper presents our analysis of the practice of compensation for non-pecuniary damage in Ukrainian law, as well as the UN Compensation Commission and the European Court of Human Rights
11 March 2024
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Evidentiary standards in the practice of the UN Compensation Commission: Lessons for Ukraine
This document contains our analysis of the practice of the UN Compensation Commission, which was established in 1991. by the UN Security Council to consider claims and pay compensation for damage and losses caused by Iraq's illegal invasion of Kuwait and subsequent occupation of Kuwait in 1990-1991.
23 Feb. 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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Best practice of asset recovery: US case of imposing liability for sanctions evasion in response to Russia’s aggression against Ukraine
An integral principle of both anti-corruption and sanctions policy should be the practical implementation of the principle "crime does not pay" and ensuring compensation for those directly or indirectly suffered from such actions.
11 Dec. 2023
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Using frozen russian assets as a means of compulsory reparations to compensate for the damage caused by russia’s aggression
The study substantiates the need to apply ‘interim’ measures aimed at collecting compulsory reparations to compensate for the damage caused by Russia's aggression against Ukraine at the expense of its frozen assets
15 Oct. 2023
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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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4 ways russian money can serve to compensate for the damage caused by the war
The study examines four ways in which sovereign Russian assets frozen in foreign financial institutions can be used to compensate for the damage caused by Russia's aggressive war against Ukraine
1 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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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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An overview of alternative instruments for stopping the war and sources of post-war recovery in Ukraine
On February 24, 2022, Russia launched a large-scale military aggression on the territory of Ukraine, violating the peremptory norms of international law (jus cogens) prohibiting the unjustified use of force.
22 Oct. 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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Conclusion on the results of the examination of the Order of the Cabinet of Ministers of Ukraine №590 “On Approval of the Procedure for the Use of Photo and Video Recording Equipment by Officials of the State Service of Ukraine for Transport Safety”
Opinion on the results of the examination of a regulatory legal act regulating the process of conducting raid inspections of carriers
9 Aug. 2022
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Policy Brief. Access of enterprises to the 1.5 billion market of providing people with disabilities with technical rehabilitation equipment. Corruption risks and practice of their implementation
This policy brief presents the findings of an independent study of corruption risks and their implementation practices in the area of providing people with disabilities with technical and other means of rehabilitation at the expense of taxpayers, including access to the market for businesses.
25 Dec. 2021
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Methodology for conducting anti-corruption expertise of draft laws
This methodology was developed by the Institute of Legislative Ideas to effectively identify provisions in laws and draft laws that, alone or in combination with other provisions, may facilitate the commission of corruption or corruption-related offenses.
27 Oct. 2021
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Policy Brief: 1.5 billion and prostheses: corruption schemes in the provision of rehabilitation equipment for people with disabilities
This policy brief presents the findings of an independent study of corruption risks and their implementation practices in the area of providing people with disabilities with technical and other means of rehabilitation at taxpayer expense, including access to the market for enterprises.
27 Oct. 2021
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Access of enterprises to the 1.5 billion market of providing technical rehabilitation equipment for people with disabilities
One of the types of social support for people with disabilities is the provision of technical and other rehabilitation equipment (TRE). This is the most expensive part of state budget expenditures to support people with disabilities, which consists of compensating enterprises for the cost of manufactured, supplied and repaired TRE without using public procurement mechanisms
19 Oct. 2021
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Sectoral systematisation of corruption-prone factors in the draft laws of the Verkhovna Rada of Ukraine of the IX convocation
This study presents the results of independent civic monitoring of corruption-prone factors in draft laws submitted to the Verkhovna Rada of Ukraine from the beginning of its 9th convocation (September 2019) to December 2020.
10 Oct. 2021
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Anti-corruption examination of draft laws Verkhovna Rada of the IX convocation
The purpose of this study is objective assessment of the anti-corruption examination of draft laws by the Parliament Committee on Anti-Corruption Policy and the National Agency on Corruption Prevention (NACP) in the new political year - between September 1, 2019, to December 31, 2020 - based on quantitative and quantitative data on the work of these agencies
1 Oct. 2021
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Activity of Parliamentary Committees in 2020: Effectiveness and Interaction with Stakeholders
The monitoring report is to present the results of independent public performance monitoring of Verkhovna Rada committees and their interaction with stakeholders during 2020.
17 Aug. 2020
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Related Materials
“Urgency” on hold: How the Verkhovna Rada has been delaying the criminalization of sanctions violations for a year
Why is the adoption of Presidential Draft Law No. 12406 still not considered a priority?
30 Jan. 2026
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Baltic Case or Prison for Violating Sanctions
How Latvia, Lithuania and Estonia implemented EU Directive 2024/1226 and strengthened responsibility for violating and circumventing sanctions against Russia.
30 Oct. 2025
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Is Punishment Inevitable? How EU Countries Criminalize Sanctions Violations
In 2024, the European Union adopted Directive 2024/1226 on the criminalization of violations of sanctions against the Russian Federation. However, in practice, the implementation process turned out to be much more difficult than expected.
20 Oct. 2025
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Registration actions and sanctions: what loopholes does Bill No. 13606 offer?
Why the government's new rules on state registration of real estate, businesses, and public organizations pose significant threats to national security and contradict European practice.
20 Aug. 2025
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Record fine for violating anti-Russian sanctions. A lesson for Ukraine
Almost every week, the world learns of new violations of anti-Russian sanctions. Violators try to avoid punishment, pursuing selfish motives, but the latest news proves the opposite
16 June 2025
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