The Independent Anti-Corruption Commission (NAKO) joined a statement by Ukrainian civil society organizations urging the Verkhovna Rada of Ukraine to improve Draft Law No. 12406. The legislation establishes criminal liability for violations of sanctions and helps align Ukrainian legislation with EU standards.
However, amendments introduced ahead of the second reading weaken its effectiveness. In particular, the updated draft:
- establishes liability only for intentional failure to comply with or obstruction of sanctions, whereas the previous version also included liability for negligent violations (Amendment No. 26);
- creates a “loophole” allowing sanctioned individuals to move assets through lawyers (Amendment No. 363);
- does not provide for a system of permits for sanctions exemptions, except for legal assistance. This mechanism, which is standard in the EU, US, and UK, allows humanitarian or other exceptional operations to proceed without breaching sanctions restrictions.
“In this context, Ukrainian civil society organizations call on the Verkhovna Rada, during article-by-article voting, not to support Amendments No. 26 and 363, and to consider Amendments No. 405, 407, and 408 to Draft Law No. 12406, in order to strengthen state sanctions policy, align it with EU approaches, and increase pressure on accomplices of aggression,” the statement reads.
The statement was also signed by members of the Public Council on Sanctions, an independent platform composed of 13 Ukrainian civil society organizations. Its goal is to increase sanctions pressure on Russia’s military-industrial complex and Kremlin partners who help circumvent restrictions. NAKO is one of the co-organizers and an active participant of the Council.
In 2024, the Council presented the Sanctions To-Do List, containing recommendations to strengthen sanctions policy against Russia.