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i It is not necessary to submit declarations, notifications of significant changes in property status and notifications on opening a foreign currency account in a non-resident bank during the war.
Clarification during the war

Ex-manager of Russia’s top energy SOEs, who has condemned putin’s regime and resigned from the company because of Russian aggression, is removed from the list of candidates for sanctions

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Ex-manager of Russia’s top energy SOEs,  who has condemned putin’s regime and resigned from the company because of Russian aggression, is removed from the list of candidates for sanctions

In order to avoid being sanctioned a sanction target identified by the National Agency on Corruption Prevention of Ukraine (NACP) shall publicly denounce Kremlin’s policies, resign from his/her position and/or take other appropriate actions. The purpose of the approach is to undermine Russia’s ability to wage war. 

This modality is set forth in the Individual Sanctions Roadmap developed within the international Yermak-McFaul Expert Group on Russian Sanctions. 

On July 4, the NACP excluded the former member of the board* of one of Russia’s largest state-owned enterprises (SOE) from the list of sanction targets. Previously, the relevant person was included in the list as the key executive of one of the TOP-10 largest companies in the Russian energy sector. This means it pays huge amounts of taxes to the Russian budget, which is in turn used to finance terrorism and, as a result, the killing of Ukrainians during the war.

The former top manager requested the NACP to be removed from the list. Because of the war, this person condemned putin’s regime and resigned from the position on the board.

Other candidates who still have a chance to avoid sanctions can find themselves on the list on the “War&Sanctions” website: https://sanctions.nazk.gov.ua/en/sanction-person-warning/

Some of the individuals identified by the NACP as those who should be imposed with sanctions have already got to the international sanctions list. Among them are the managers of the industrial conglomerate Rostec, namely member of the board and Deputy Director Igor Zavyalov, Deputy Director Maxim Vybornykh, and Internal Audit Director Natalya Smirnova. All of them have already got to the US sanctions lists. If they had resigned from their positions in advance, they probably would have had a chance to avoid sanctions and seizure of assets.

The exit strategy to be removed from the list of sanction targets is available via this link: https://sanctions.nazk.gov.ua/en/avoid-sanctions/ or e-mail press@nazk.gov.ua.

* The name of the person is withheld for privacy reasons. When applying to NACP for exclusion from the list of candidates for sanctions, you can be sure that your data will remain safe.

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Ex-manager of Russia’s top energy SOEs, who has condemned putin’s regime and resigned from the company because of Russian aggression, is removed from the list of candidates for sanctions
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