Ukraine discontinues War and Sanctions Portal

Ukraine

Following a governmental discussion on 19 March 2024, the Ukrainian government announced its decision to shut down a sanctions-related database maintained by the National Agency on Corruption Prevention (NACP).

This database, the “War & Sanction Portal”, was created in the first days of Russia's full-scale invasion of Ukraine as part of the implementation of the sanctions plan against Russia (i.e. the Individual Sanctions Roadmap) of the Yermak-McFaul Sanctions Group.

Starting with the "International Sponsors of War" section, the Portal was expanded to include additional segments such as "Components in Weapons", "Tools of War", "Candidates for Sanctions", "War and Art", "War and Sports", and "Foreigners in Russian Companies".

While inclusion on the Portal’s lists did not entail immediate legal consequences, the Portal was used to pressure listed entities and individuals to withdraw from doing business in or with Russia. As a result, some voluntarily withdrew from business in or with Russia, effectively demonstrating the impact of the NACP’s Portal.

Prior to the launch of the State Register of Sanctions on 1 February 2024, the Portal served as the sole mean to access consolidated information about individuals and entities subject to Ukrainian sanctions.

The Ukrainian government cited the lack of a regulatory framework for the Portal’s existence as one of the reasons for discontinuation. Additionally, it was communicated that all official information regarding imposed sanctions is adequately covered by the State Register of Sanctions.

On 22 March 2024, the NACP discontinued the Portal and redirected visitors to the website of the State Register of Sanctions.  All the data and documentary materials contained in the "International Sponsors of War" section of the Portal have been provided to the Interagency Working Group on the Implementation of the State Sanctions Policy for further assessment.

For more information on the sanction regime in Ukraine, contact your CMS advisor or our local CMS team of experts: Olga Shenk, Oleksandr Protsiuk.