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Business discussed the sanctions draft law with the Ministry of Justice and the Institute of Legislative Ideas

30/ 01/ 2025
  On 29 January, the European Business Association held a meeting with the Deputy Minister of Justice of Ukraine, Inna Bohatykh, representatives of the Ministry’s Sanctions Policy Department, the Head of the analytical centre Institute of Legislative Ideas, Tetiana Khutor, and the centre’s team. The discussion focused on Draft Law No. 12406, which aims to establish liability for violations of special economic and other restrictive measures (sanctions) and strengthen responsibility for sanctions breaches. As noted by representatives of the Ministry of Justice, the Law of Ukraine On Sanctions has been in place for over 10 years, but its provisions have been applied most actively since 2022. Consequently, the issue of monitoring compliance with sanctions has gained new relevance. Draft Law No. 12406 aligns with EU Directive 2024/1224 and introduces the criminalisation of the most severe financial sanctions violations. It defines sanctions evasion as a distinct criminal offence, sets a monetary threshold for violations, and establishes liability for negligent breaches. Additionally, the bill includes an incentive provision that allows for mitigation of punishment in cases of cooperation with the investigation. The ЕВА appreciates all participants for their engagement and dialogue. In the near future, its experts will submit proposals for refining certain provisions of the bill to ensure clarity and avoid ambiguous interpretations.

On 29 January, the European Business Association held a meeting with the Deputy Minister of Justice of Ukraine, Inna Bohatykh, representatives of the Ministry’s Sanctions Policy Department, the Head of the analytical centre “Institute of Legislative Ideas,” Tetiana Khutor, and the centre’s team.

The discussion focused on Draft Law No. 12406, which aims to establish liability for violations of special economic and other restrictive measures (sanctions) and strengthen responsibility for sanctions breaches.

As noted by representatives of the Ministry of Justice, the Law of Ukraine “On Sanctions” has been in place for over 10 years, but its provisions have been applied most actively since 2022. Consequently, the issue of monitoring compliance with sanctions has gained new relevance.

Draft Law No. 12406 aligns with EU Directive 2024/1224 and introduces the criminalisation of the most severe financial sanctions violations. It defines sanctions evasion as a distinct criminal offence, sets a monetary threshold for violations, and establishes liability for negligent breaches. Additionally, the bill includes an “incentive provision” that allows for mitigation of punishment in cases of cooperation with the investigation.

The ЕВА appreciates all participants for their engagement and dialogue. In the near future, its experts will submit proposals for refining certain provisions of the bill to ensure clarity and avoid ambiguous interpretations.

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