Sanctioned assets are helping to rebuild Ukraine

For more than four years now, the Ministry of Justice has been acting as the authority responsible for initiating the seizure of assets belonging to sanctioned individuals.

The mechanism provides not only for the seizure of property directly owned by a sanctioned individual. Following amendments to the Law of Ukraine ‘On Sanctions’ in May 2022, it also extends to assets in respect of which a person, directly or indirectly, carries out actions equivalent in substance to exercising the right to dispose of them. In other words, this refers, in particular, to property that is formally registered in the names of other persons but is in fact controlled by the sanctioned individual.

For this reason, before applying to the High Anti-Corruption Court, the Ministry of Justice must gather evidence – substantiating and proving the existence of grounds for the confiscation of assets (the list of which is defined by law) – and identify those assets that belong to or are controlled by the sanctioned person.

Since this mechanism came into force, the Ministry of Justice has filed 83 claims with the High Anti-Corruption Court seeking the confiscation of assets belonging to sanctioned individuals for the benefit of the state. Following the consideration of these cases, court rulings have already been handed down in 79 cases, whilst four major sanctions cases are currently pending before the court of first instance (991/5746/23; 991/5770/24; 991/11063/24; 991/4643/26). Through final and binding court decisions of the High Anti-Corruption Court (HACC) and the HACC Appeals Chamber, sanctions in the form of the confiscation of assets for the state’s benefit have been imposed on 96 sanctioned individuals.

These are assets on a significant scale. Following claims by the Ministry of Justice, the following have already been confiscated for the state: corporate rights in 135 companies; 345 properties; 356 vehicles; seven aircraft; four seagoing vessels; and claims totalling over 2.5 billion UAH.

In addition, cash amounts totalling over 732 million hryvnias, 17.4 million US dollars and 869,000 euros have been seized, as well as other assets, including property rights, trade marks, railway carriages, mineral resources and so on.

Among the most significant assets are the ‘Mezhyhiria’ residence (Tantalit LLC), the Ocean Plaza shopping centre (IS ‘Lybid’ LLC), Mykolaiv Alumina Plant LLC, Demurinsky Mining and Processing Plant Ltd, AEROK Ltd, Vinnytsia Pobutkhim Public Joint-Stock Company, Motor Detal-Konotop Ltd, AMSTEL-SKI Ltd, Kalush Pipe Plant Ltd, Eurotrubplast Trading House, Tatneft-AZS-Ukraine LLC, Kharkiv-Capital LLC, Poltava-Capital LLC, Nasosenergomash JSC, Sumy NVO JSC, Kirovograd Ore Management JSC (52.7 per cent); JSC ‘Kryukiv Railway Car Building Plant’ (25 per cent), two AN-148-100E passenger aircraft; mineral resources (potash, bauxite, iron ore).

Once the court ruling has become final, the state, represented by the State Property Fund of Ukraine, becomes the owner of the seized assets and ensures they are prepared for sale through open auctions on the Prozorro.Sales platform.

The proceeds are channelled to the Fund for the Elimination of the Consequences of Armed Aggression and used for the reconstruction of Ukraine.

The State Property Fund of Ukraine has already sold a number of sanctioned assets, in particular through large-scale and small-scale privatisation, as well as in accordance with the special procedure for the sale of sanctioned property. Thus, as of August 2026 (according to the State Property Fund of Ukraine), proceeds from the sale of such assets exceeded 2.7 billion UAH, of which nearly 90 million UAH was received in 2026. All funds have been channelled to the Fund for the Elimination of the Consequences of Armed Aggression.

“The Ministry of Justice continues its systematic work on improving the legal mechanisms of sanctions policy, establishing consistent case law and ensuring the effective recovery of assets belonging to sanctioned individuals for the state’s revenue,” said Olena Vakulenko, Director of the Department of Sanctions Policy and Court Representation.

Source: Ministry of Justice of Ukraine