On 22 February 2023, the Countrywide Stability and Protection Council of Ukraine released a set of sectoral exclusive financial and other restrictive steps (sanctions) in opposition to the Russian banking and economical sector.[1] This is the to start with set of anti-Russia sectoral sanctions imposed by Ukraine.
To come to be effective, the Selection will have to 1st be accepted by a resolution of the Ukrainian Parliament in 48 several hours.[2]
The sanctions will utilize for 50 decades to the adhering to entities offering monetary providers and registered or situated in the Russian Federation:
- all banking companies, including the Central Lender of the Russian Federation,
- non-lender credit rating establishments, payment units operators, professional stock industry contributors, insurance businesses, investment decision money and other institutions furnishing fiscal products and services,
jointly (“Russian Money Establishments“).
The sanctions deliver for:
- suspension of transactions involving belongings owned by the Russian Money Institutions
- prohibition on setting up enterprise relations (like correspondence relations) with the Russian Economical Establishments
- prohibition on executing transactions with the Russian Financial Establishments
- prohibition on sustaining business relations (such as correspondence relations) with the Russian Economic Institutions
- prohibition on the buy of securities and other monetary devices issued by the Russian Money Institutions (except for the alienation of these securities (which includes totally free of demand) in favor of Ukraine)
- suspension of the overall performance of economical and financial obligations (which include the transfer of dividends, interest payments and other payments) in favor of the Russian Economical Establishments
- prohibition on investments in or in favor of the Russian Economical Institutions
- suspension of the service of digital means of payment (together with transfers, settlements and income withdrawals) issued by the Russian Economic Establishments
- prohibition on crediting resources to the accounts of people today / lawful entities underneath transfers initiated by electronic usually means of payment issued by the Russian Economical Establishments
- cancellation of registration and prohibition on further more registrations by the National Bank of Ukraine of the adhering to:
- the intercontinental payment program — if its operator is a Russian Economical Institution
- a participant of the intercontinental payment program — if the operator of the global payment process is a Russian Economic Establishment
- a participant (Russian Money Establishment) of the global payment procedure — if the operator of the international payment process is a resident of Ukraine.
People and authorized entities are prohibited from executing transactions aimed at the circumvention of the above restrictions. The Determination will become effective on the working day it is accredited by the Ukrainian Parliament.
[1] Presidential Decree No. 89/2023 dated 22 February 2023 “On the Conclusion of the Nationwide Security and Defense Council dated 22 February 2023 ‘On Imposing Sectoral Specific Financial and other Restrictive Steps (Sanctions) versus Fiscal Establishments of the Russian Federation’” (“Final decision“).
[2] Artwork. 5 (2) of Legislation of Ukraine “On Sanctions” dated 14 August 2014 No. 1644-VII.
Writer
Hanna Shtepa
Hanna Shtepa is a Counsel heading the Intercontinental Professional & Trade (ICT) exercise in the Kyiv business office of Baker McKenzie. The follow is rated Tier 1 by Lawful 500 EMEA. She specializes in worldwide trade limitations, financial sanctions and export controls compliance, structuring worldwide provides of merchandise and services, anti-dumping investigations, general public procurement regulations, trade and standard compliance, authorized routine and restrictions similar to non permanent occupied territories and enterprise functions through the army point out. She also has intensive practical experience in undertaking finance, concentrating on renewable and traditional strength, financial restructuring, sovereign and municipal finance, nuclear liability. Hanna is rated as Following Technology Spouse for Worldwide Trade and Power and suggested as a Increasing Star in Banking, Finance and Money Markets by Authorized 500 EMEA 2020-2022. 


Ms. Shtepa retains her LL.M. in Intercontinental Commercial Arbitration Legislation from the Stockholm College, Stockholm, Sweden.
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