Ukraine systematically adds companies from Russia, Hong Kong, the UAE, and Kyrgyzstan to sanctions lists. It coordinates these decisions with partners and synchronizes them with EU packages. However, there is one entity that Ukrainian sanctions mechanisms essentially do not touch — a Ukrainian citizen who supplies goods to the Russian defense industry.
This was stated openly by Vladislav Vlasiuk, the Presidential Commissioner on Sanctions Policy: Ukraine still lacks a law on criminal liability for violating sanctions restrictions, and parliament has not closed this gap.
"I am very concerned about the absence in Ukraine of a law on criminal liability for violating sanctions restrictions. This looks like a serious gap in legislation that parliament has not yet closed."
Vladislav Vlasiuk, Presidential Commissioner on Sanctions Policy
What exists now — and what is missing
Ukraine can freeze assets, restrict transactions, and add entities to lists. However, criminal prosecution for the mere fact of circumventing sanctions is outside the scope of the current Criminal Code. This means: if a Ukrainian intermediary company supplies microelectronics to Russia through third countries, it is legally difficult to punish its owner for this. An administrative fine is possible. Criminal proceedings specifically for violating sanctions — no.
As noted in an analysis by the Institute of Legislative Ideas, published in "Evropeiska Pravda," implementation among EU countries is also not without problems: Greece, Spain, Malta, Germany, Poland, and Romania are still discussing drafts of relevant laws, while Italy is lagging behind by at least a year. However, Finland has become a benchmark — it adopted a package of four coordinated laws simultaneously in April 2025, ensuring systemic consistency without gaps between norms.
The Finnish model: why it matters
Finland implemented EU Directive 2024/1226 on criminal liability for violating sanctions — and did so as a package. From May 20, 2025, new articles (3a–3d) appeared in the Finnish Criminal Code, defining the elements of the crime and liability. An important nuance, which the law firm Borenius points out: the new norms apply extraterritorially — meaning they extend to Finnish citizens even if the crime was committed abroad and is not criminally punishable there. In cases of aggravating circumstances — up to five years imprisonment.
It is precisely this principle — holding a citizen accountable regardless of where the crime was committed — that Ukraine lacks. An intermediary scheme through third countries becomes legally vulnerable only when the state can prosecute its own citizen for participation in it wherever they are located.
Parliament knows — and says nothing
Relevant bills in Ukraine have been registered since 2022 — including draft law №8384. None have become law. The reasons include discussions about the scope of criminal liability, concerns about conflicts with the ne bis in idem principle (one cannot be punished twice for the same offense), and the general overload of parliament's agenda under the conditions of war.
Vlasiuk, citing Finnish experience as a benchmark, essentially acknowledges: Ukraine lags behind the standard it itself demands from partners when synchronizing sanctions decisions. A country that forms sanctions lists for dozens of jurisdictions does not have an internal criminal lever against its own violators.
If the Rada does pass a law with extraterritorial application — will Ukraine be ready to actually implement it, or will the norm remain declarative without the appropriate investigative capacity in the SBI and SBU?
