Comparison of international, Ukrainian sanctions against individuals and entities supporting Russian aggression

Read about how synchronized Ukrainian sanctions are with international special restrictive measures and which of the "sanctioned" had the greatest impact on the Ukrainian economy in the study by YouControl R&D Center and PhD, financial analyst Roman Kornyliuk.

Personal sanctions: dynamics over the past 10 years

Personal special economic sanctions, along with sectoral sanctions and restrictions, are still the key methods of non-military struggle against aggressor countries. The peak number of sanctions imposed in 2022 was 15,205. At the same time, if we focus on the sanctions imposed by the National Security and Defense Council of Ukraine (NSDC), the peak occurred in 2023, with 6,300 sanctions issued, surpassing the previous year's figures of nearly 5,000.

Comparison of international and Ukrainian personal sanctions against Russian aggression

The graph of the dynamics of the intensity of sanctions shows that:

* Sanctions against Russians were imposed from the very beginning of the Russian-Ukrainian war, starting with the annexation of Crimea and the seizure of Ukrainian cities in Donetsk and Luhansk regions in 2014. 

* Initially, the intensity of personal sanctions was low, at the level of 200-800 sanctions from all jurisdictions, which did not allow sanctions pressure to fulfill its preventive role in preventing a full-scale invasion.

* Despite the fact that the NSDC's sanctions activity increased significantly in 2021 - up to 2,500 people - this was not reflected in a proportional increase in sanctions from Ukraine's international partners, who imposed only 174 sanctions in 2021.

* The maximum levels of sanctions pressure on Russia and Belarus by the international community, namely: USA, EU, UK, Japan, Australia, Canada, Switzerland, New Zealand and Poland, were recorded after the fact in 2022 - with over 15,000 sanctions.

* The number of international sanctions imposed in the first half of 2023 dropped significantly, decreasing by several times to 3,900 sanctions, many of which are duplicated from country to country.

Which jurisdictions were the first to impose sanctions?

YouControl R&D Center analysts additionally analyzed the dates of imposition of sanctions on each toxic person from the War and Sanctions portal database. The EU was among the leaders in imposing sanctions, having sanctioned 1,087 individuals. This accounts for 28.5% of the total number of individuals who are simultaneously sanctioned by the NSDC and at least one other international jurisdiction. The second place is occupied by the US, which was the first to initiate 1,033 sanctions (27.1%). The NSDC is in third place with 699 sanctions. In terms of the dates of implementation, Ukraine was the first to initiate sanctions against only 18.3% of the "sanctioned" individuals within the "internationally recognized" subsample of 3,815 toxic individuals. Currently, there is a much larger number of individuals against whom the NSDC has sanctioned, but the international community has not responded with appropriate actions - 11,098 legal entities and individuals. 

Discrepancies in the sanctions policy of Ukraine and the world

As of November 2023, the total number of individuals and legal entities under sanctions in the database of the War and Sanctions portal is 16,919. Of these, 10,126 are individuals and 6,793 are companies. At the same time, 14,913 people are under sanctions imposed by the National Security and Defense Council, 5,821 people are under international sanctions imposed by foreign jurisdictions, and 3,815 people from both groups are simultaneously under Ukrainian and international sanctions. The most interesting segment of the analyzed samples for further research can be considered 2,006 sanctioned persons (1,238 companies and 768 individuals), who, despite the existing international sanctions, are not on the NSDC sanctions lists for one reason or another. 

Connections of known sanctioned persons

In terms of the revenue generated by the Ukrainian business assets currently or previously controlled by the sanctioned persons, the most economically influential sanctioned persons are the following beneficiaries: Dmytro Firtash, Vadym Novynskyi (who are subject only to NSDC sanctions), Viktor Medvedchuk, and the Russian beneficiaries of VS Energy International (Babakov, Giner, and Voevodin).

YouControl has compiled a list of the 60 largest Ukrainian companies by revenue and assets in 2022 whose participants/beneficiaries/shareholders are subject to sanctions. They are members/associates or belong to 15 financial and industrial groups (FIGs) added to the analytical system. In particular:

• 14 companies that are part of the Group DF.
• 5 companies from Smart-Holding.
• 4 companies of VS Energy International
• 3 companies that are part of/have links to SCM

Dmytro Firtash, a key personality of the Group DF, was sanctioned by the National Security and Defense Council in June 2021. Since 2014, he has been living in Austria under his own recognizance. About half of the companies of the Group DF  on the list are involved in the production and sale of chemical products. The list also includes several gas supply companies (LLC TVIY GASZBUT, LLC YE Energy).

The key person in Smart-Holding is former MP Vadym Novynskyi. He was sanctioned by the National Security and Defense Council in December 2022. Novynskyi is the beneficiary of 4 companies (SMART ENERGY LLC, Kharkivoblenergo JSC, Ukrgazvydobutok PJSC, and Smart Leasing LLC). 

Three shareholders of PJSC Zaporizhstal: FDI Kyiv Securities Group LLC (24.5%), Midland Capital Management LLC (11.22%) and the British company GLOBAL STEEL INVESTMENTS LIMITED (12.34%), were included in the NSDC sanctions list in May 2023. The Dutch company METINVEST B.V. owns 47% of the company's shares. According to the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations (USR), the beneficiary of Zaporizhstal is the key person of SCM FIG Rinat Akhmetov. 

Notifications of sanctions restrictions on the shareholder of Kryvbaszalizrudkom JSC and beneficiaries of Kirovohradoblenergo PJSC have been added to the YouControl system. Kirovohradoblenergo is a part of the FIG VS Energy International, which unites 5 energy distribution companies. In particular, the aforementioned Kirovogradoblenergo, as well as Zhytomyroblenergo, Chernivtsioblenergo, Rivneoblenergo, and Khersonoblenergo.  The key persons of this FIG - Arthurs Altbergs, Oleh Sizerman, Maryna Yaroslavska, Willis Dumbins and Valts Vigants - were included in the NSDC sanctions list in May 2023. In the article of Ekonomichna Pravda dated 21.07.2022 "Case VS Energy. Why the courts do not see Russians behind straw men and relatives" states that these companies and individuals are associated with Russian oligarchs (Alexander Babakov, Yevgeny Giner and Mikhail Voevodin), who are also under sanctions in Ukraine. 

Almost all of the companies on the list have sanctioned persons as participants/shareholders/CEOs. The exception is Freedom Finance Ukraine LLC, which was directly included in the NSDC sanctions list in October 2022. The company is a part of Freedom Holding Corp. whose key person is Timur Turlov (also included in the NSDC sanctions list).

How to find out if a counterparty is under sanctions

Ukraine’s national and international sanctions against legal entities and individual entrepreneurs are displayed in YouControl. You can check not only the sanctions imposed directly on the counterparty, but also on related parties. Just go to the company's card and if sanctions are imposed, the Express Analysis tool will immediately show it.

You can also identify a sanctioned individual. Just enter the name of the person in the individual verification module, and if he or she is under sanctions, the system will show it. The section of the same name contains a list of all sanctions imposed on an individual, where you can see the date of application of each of them. And the NSDC Sanctions section contains the grounds for applying personal special economic and other restrictive measures (sanctions) and the period of their application.