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Four years of NACP 2.0: sanctions policy

15.01.2024

New challenges require new approaches. After the beginning of Russia's full-scale invasion of Ukraine, the NACP team realized that it could not limit itself to the work it had done in peacetime. The Agency continued to perform its functions, adapting to the changes and realities of wartime, and joined the fight against the aggressor on the sanctions front.

On February 25, 2022, at the request of the Ministry of Foreign Affairs of Ukraine and the Office of the President of Ukraine, the NACP began preparing lists of candidates for sanctions. After the Yermak-McFaul Sanctions Group (Stanford International Working Group on Sanctions against the Russian Regime) was established at the initiative of President of Ukraine Volodymyr Zelenskyy, the NACP officially launched the War and Sanctions portal as part of the Roadmap for Individual Sanctions.

"Ukraine has changed the rules of the game on the global sanctions track and is actively promoting the values of integrity in international sanctions policy. The War and Sanctions portal has become the world's main resource on anti-Russian sanctions. Here everyone can find sanctions lists of Russians and international corporations that have not withdrawn from Russia, Ukrainian cultural heritage stolen by Russia, and foreign components in Russian weapons," said NACP Head Oleksandr Novikov.

"War and Sanctions" is real proof that transparency and accountability are effective tools to counteract autocracies that use corruption as a weapon," said Agiya Zagrebelska, Head of the Department for Minimizing Corruption Risks in the NACP Sanctions Policy.

The tool "International Sponsors of War" has become a real identifier of dishonest companies that finance the war against Ukraine and make a significant contribution to the Kremlin's military aggression: taxes, technology, propaganda, and participation in mobilization. The portal's data is used by world leaders in the world of compliance, namely Refinitiv WorldCheck and Doe Jones. The portal is constantly monitored by the world's leading banks, consulting firms, law firms, and audit firms. Most importantly, people around the world refuse to buy goods and services from companies that have chosen a bloody reputation over the values of democracy and integrity.

Due to the reputational impact of this tool, such companies as Peninsula Petroleum Limited, Mondi, Thenamaris Ships Management Inc., Minerva Marine, TMC Tankers LTD, and Shree Ramkrishna Exports left the Russian market, as well as companies such as Etex, Raiffeisen Bank International, and Danieli & C. S.p.A. These are powerful blows to the aggressor's economy, which will continue in the future.

The NACP team identified more than 24 thousand individuals and legal entities involved in Russia's war against Ukraine. Information about them was sent to the Security Service of Ukraine, the National Security and Defense Council of Ukraine, the Ministry of Foreign Affairs, and the countries of the sanctions coalition, and published in the section "Candidates for sanctions". The module "Sanctions Lists" has become the main resource that displays information on the application of sanctions by Ukraine and other countries of the sanctions coalition.

The NACP is also a member of the Interagency Working Group on the Formation and Implementation of Sanctions Policy (IWG), coordinated by First Vice Prime Minister Yulia Svyrydenko. Over the course of the IWG's work, sanctions have been imposed on more than 12,000 individuals (7,147 individuals and 5,511 legal entities) and enforced by Presidential Decrees.

The National Agency, in particular, prepared and ensured the adoption of a draft law on the confiscation of property of sanctioned persons (No. 7194). Ukraine became the first country to introduce the possibility of confiscating the assets of the aggressor and its accomplices at the legislative level. Thus, based on the NACP's materials, assets of sanctioned persons totaling more than UAH 5 billion were recovered in favor of the state based on court decisions. Among the most high-profile names of Russian oligarchs whose assets were recovered in favor of the state using the NACP's materials are Vladimir Yevtushenkov, Oleg Deripaska, Arkady, and Igor Rotenberg.

However, Russian oligarchs, despite the sanctions imposed on them, can still hide and launder their money through, for example, art objects. Thus, paintings, sculptures, and artistic jewelry are used as a loophole to circumvent sanctions. It is to prevent this and search for the artistic assets of sanctioned Russians that the NACP launched the War and Art project.

In the War and Art section, you can find art objects owned by sanctioned persons or sold or bought by them since 2014, the beginning of the Russian-Ukrainian war. All these art objects are united in one database, which makes it easier for honest participants to conduct "sanctions" checks and more difficult for Russian oligarchs to sell such assets. Currently, the section includes 1323 art objects owned by Russian oligarchs, of which 232 art objects have been valued at USD 2,715,852,951. Also, 235 objects of cultural heritage from Ukraine that have been stolen or are under threat of being stolen by the Russian Federation have been identified.

However, in times of war, weapons remain a key factor. And while the sanctions continue to work against the aggressor's military-industrial complex, there is increasing information that foreign components are found in Russian weapons or equipment destroyed by our military. 

The world must unite around the non-proliferation of its technologies to aggressors, so the NACP has launched the world's first and only open database of foreign components in weapons. The database already includes more than 2,800 foreign components found in Russian and Iranian weapons. These are "Shaheds," "Kalibrs," other various types of UAVs, missiles, electronic warfare systems, and many other types of weapons and military equipment. 

The NACP has received a lot of feedback from the Ukrainian military and international partners regarding the usefulness of our base as a tool for demilitarizing the Russian Federation. The Agency also expresses its gratitude to all Ukrainian military personnel who seize these weapons, as well as to research centers for studying and identifying these components.

Each of these projects has been made possible through the NACP's cooperation with various civil society organizations and investigative journalists around the world. Thousands of volunteers have contributed to the creation and development of these tools to put pressure on the aggressor. We continue to work for victory and destroy the economic and military potential of the terrorist state together!

The analytical report on the NACP's work for four years (2020–2023) is available here.

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