As a Compliance Officer, I see the same mistake every day: investors continue to think that sanctions are the counterparty’s problem. In 2026, this is no longer the case.
Today, an investor is jointly and severally liable for sanctions violations, even if he is not a resident of the Russian Federation. Secondary sanctions, automatic AI monitoring, and increased control in Ukraine are doing their job.
The consequences can be very severe:
• blocking of assets and actual freezing of access to resources;
• restriction or complete suspension of trading operations;
• suspension of economic and financial obligations;
• cancellation or suspension of licenses, permits, and other rights to conduct activities, as well as a ban on the withdrawal of capital from Ukraine.
These are the tools directly provided for by the Law of Ukraine “On Sanctions”
The legislative trend in Ukraine goes further: bill 12406 of 14.01.2025 provides for criminal liability not only for violation of sanctions, but also for their intentional circumvention – with fines, restriction of the right to hold positions, imprisonment, and in some cases, confiscation of property. For business, this is a clear signal: sanctions compliance can no longer be a formality – it is a matter of personal and corporate responsibility.
What every investor should do right now:
- Conduct full due diligence to the level of ultimate beneficiaries
- Regularly check counterparties for sanctions
- Include strict sanctions provisions in investment agreements
- Build constant sanctions monitoring into processes.
Investing today means taking full responsibility for who you invest with. Ignoring sanctions risks is no longer a savings, but a direct threat to business.