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effective date March 21, 2023, Ukraine A new set of personal sanctions have been imposed on 300 people personal and 141 legal entities aimed at targeting the Russian military industry as well as Iranians, Syrians, and Emiratis who contributed to Russia’s aggression against Ukraine.[1]
Decide Imposition of wide-ranging sanctions, including freezing of assets; prohibition of trade operations; prohibition of transit of resources, flights and transport within Ukraine; suspension of economic and financial obligations; restriction of capital outflows from Ukraine; banIssues concerning participation in privatization and leasing of state property; suspension or suspension of licenses and other permits; prohibition of technology transfer and rights of intellectual property objects. The specific set of sanctions applicable to each sanctioned person is set out in the annex to the decision.
Sanctions affect, inter alia, the following categories of persons:
- Russian legal entities involved in the Russian military industry and its management – JSC “Concern “Kalashnikov”, Joint-Stock Society “Aerospace defense concern “Almaz-Antey”, JSC “Automobile plant “Ural”, JSC “Plant “Universalmash”, etc.
- Enterprises located in the temporarily occupied areas of Ukraine – autonomous non-profit organization “Institute of Marine Instrumentation and Robotics”, JSC “Evpatoria Aircraft Repair Plant”, etc.
- Executives of the Iranian military and companies engaged in the production of unmanned aerial vehicles (UAVs) – Aghajani Saeed Ara Jani, Commander of the Aerospace Forces of the Islamic Revolutionary Guard Corps; Mehrabi Abdollah, Chief of the Aerospace Forces of the Islamic Revolutionary Guard Corps; Oje Parvaz Mado Nafar ) Managing Director, Abutalebi Yousef et al
- Iranian companies involved in the production and transportation of drones and other military products – Paravar Pars Company, Aircraft Engine Design and Manufacturing Company (DAMA), Baharestan Kish Company, Oje Parvaz Mado Nafar Company (Mado), Safiran Airport Services, Shahed Aviation Industries Company, Iran Aircraft Industry Company, etc.
- Senior Syrian Officials – Bashar Hafez al-Asad, Husein Arnus and Feisal al-Mikdad
- UAE Firm Facilitates Transfer of Iranian Drones to Russia – I Jet Global DMCC and Success Aviation Services FZC
A full list of sanctioned individuals and legal entities is attached to the decision.
Any party dealing with individuals on a sanctions list must carefully assess the exact scope of sanctions imposed and the implications of dealing with these entities and individuals.
[1] Presidential Decree No. 163/2023 of March 18, 2023 “On the Decision of the National Security and Defense Council of March 18, 2023 ‘On the Implementation and Modification of Special Economic and Other Restrictive Measures (Sanctions) for Individuals'”Effective from March 21, 2023 (this”Decide“).
author
Hannah Stepa
Hanna Shtepa is legal counsel in the International Commerce and Trade (ICT) practice in Baker McKenzie’s Kiev office. The firm is rated Tier 1 by Legal 500 EMEA. She specializes in international trade restrictions, economic sanctions and export control compliance, structuring international supply of goods and services, anti-dumping investigations, public procurement regulations, trade and general compliance, legal regimes and restrictions related to temporary occupation of territories and business operations. militarism. She also has extensive experience in project finance, focusing on renewable and conventional energy, financial restructuring, sovereign and municipal financing, nuclear liability. Hanna has been named a Next Generation Partner in International Trade and Energy by Legal 500 EMEA 2020-2022 and recommended as a Rising Star in Banking, Finance and Capital Markets. Ms. Shtepa holds a Master of Laws degree. International Commercial Arbitration Law, Stockholm University, Stockholm, Sweden.
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