The NACP 2.0. Sanctions policy-2022: participation in the creation of sanctions plans, the “War and Sanctions” portal, assets of Russians and the search for foreigners in Russian companies

After the full-scale invasion of Russia into Ukraine, the NACP continued not only to fulfill its direct duties, but also quickly adapted to the changes and realities of wartime.  In addition to the fight against the internal enemy – corruption, our team joined the fight against the terrorist-state on the sanctions front.

“After the beginning of the war, it became clear to the NACP team should not limit itself exclusively to its peacetime work.  Everyone has to do their best to win.  After the creation of the Individual Sanctions Roadmap by the The International Working Group on Russian Sanctions, which defined the role of the NACP in the sanctions policy, our team began preparing lists of candidates for sanctions.  More than 24,000 individuals and legal entities involved in the initiation and conduct of Russia’s war against Ukraine were identified.  This is a powerful result.  But there are many more people to blame for the war, so the work continues”, — said Agia Zagrebelska, the head of the direction of minimization of corruption risks in the sanctions policy of the NACP.

The NACP is a member of the Interagency Working Group (IWG) on implementation of the state sanctions policy, the work of which is coordinated by the First Deputy Prime Minister – Minister of Economy of Ukraine.  During the work of the IWG, sanctions were imposed on almost 4,500 persons (3,113 individuals and 1,374 legal entities), which were put into effect by presidential decrees.

The NACP has always been an anti-corruption IT hub, digitalizing most anti-corruption processes.  Understanding the challenges faced by the state, the Agency together with the Ministry of Foreign Affairs (MFA) launched the innovative “War and Sanctions” Portal, which became the largest global database of individual sanctions in the world.  The Portal information is integrated into OpenSanctions, other sanctions databases and compliance systems around the world.

A separate section “Orchestra of annexation” appeared within the Portal after Putin’s announcement of the “accession” of a part of the occupied Ukrainian territories to Russia.  In the St. George’s Hall of the Kremlin, the political elite of Russia gathered at that time: deputies of the State Duma, senators of the Federation Council, ministers, heads of regions, law enforcement officers, religious figures, media persons, etc.  In a matter of days, those present in the hall were identified by the NACP analysts, and the State Security Service submitted proposals to the IWG regarding the sanctioning of those on whom sanctions had not yet been imposed.

The NACP experts also launched a Portal for Whistleblower notifications about the assets of persons involved in the aggression of the Russian Federation against Ukraine, thanks to which anyone who has information about the assets of such persons can report them.  After that, the information will be verified, and the assets will be frozen in the future and used for the reconstruction of Ukraine.

In addition, at the beginning of the war, the NACP began to search for foreigners in the management bodies of the largest Russian companies.

“As long as the sanctions work against Russian companies, we must do everything to make working with Russians a shame for every foreigner.  Thus, since the beginning of the war, the Agency’s analysts processed the data of more than 2,200 Russian companies, in 300 of which we identified almost 700 foreigners who worked in the management and supervisory boards of these companies.  All of them were included in the list of shame of foreigners, which was formed by the NACP”, — stressed the deputy head of the department – the head of the unit of the Department for the Prevention of Political Corruption Maryna Barynina.

Since the beginning of work on the project, the NACP has sent 445 warning letters, of which:

•  354 letters – to the headquarters and largest offices of 48 personnel agencies of the world to inform about foreigners who cooperate with Russian companies;
•  64 letters – to the places of work of such foreigners abroad;
•  27 letters – to professional organizations whose members are foreigners working in the Russian Federation.

Also, the NACP partners sent a number of letters to the personal e-mail addresses of such foreigners.

As of the end of 2022, 350 foreigners remained working in 150 Russian companies – half of the persons identified by the Agency for the period since the beginning of the armed aggression of the Russian Federation against Ukraine.  Therefore, the work to “facilitate” their release from the companies of the aggressor country continues.  In addition, the NACP analysts search and identify foreigners who work in the management and supervisory boards of a number of other Russian companies that supplement the budget of the Russian Federation with taxes.

Among the new challenges for the NACP was also the search for assets of sanctioned persons with the aim of further confiscation into state revenue.  Thus, the NACP carried out an asset search and provided information at the request of the Ministry of Justice of Ukraine regarding 705 individuals and legal entities. 

“The materials of the NACP have already helped to confiscate the assets of Vladimir Yevtushenkov, the chairman of the board of directors and owner of shares of Sistema AFK, which owns the RTI Sistema concern, which is one of the hundred largest defense companies in the world and which develops control and communication systems for the Russian military machine.  as well as the assets of the ex-president of Ukraine Viktor Yanukovych.  Now these assets will serve for the benefit of Ukraine, work on others continues”, – stressed Andrii Pasichnyk, head of the department for conducting full inspections.