A New Procedure for the Sale of Sanctioned Assets Has Been Introduced

On 21 January 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 75, approving a special Procedure for the sale of assets subject to a court decision imposing sanctions under subclause 1-1 of Clause one of Article 4 of the Law of Ukraine “On Sanctions”. The new Procedure is aimed at improving the mechanisms for disposing of sanctioned property, considering its legal characteristics and economic feasibility.

The introduced Procedure provides, in particular, for:

  • conducting electronic auctions with the possibility of reducing the starting price;
  • applying an auction procedure involving a step-by-step reduction of the starting price and submission of price bids by participants (in the form of a so-called “Dutch” auction);
  • introducing flexible mechanisms for the management of claims, including the possibility of using such claims as contributions to a company’s charter capital;
  • allowing the consolidation of assets into pools – a set of assets for which a court decision on the application of sanctions has been made and which are combined into a single lot.

It is expected that these mechanisms will ensure a more efficient and competitive sale of sanctioned assets in accordance with the requirements of sanctions legislation.

Proceeds from the sale of such assets are planned to be transferred to the state budget and subsequently used to finance the restoration of infrastructure, the economy, and support for citizens through the Fund for the Elimination of the Consequences of Armed Aggression.

In addition, a list of assets approved for sale under the new procedure during 2026 has been adopted. This list includes corporate rights in 26 business entities, in particular companies operating in the industrial, trade, and processing sectors.

The launch of electronic auctions is scheduled for March 2026, subject to the readiness of each individual asset for sale.

We will continue to closely monitor further developments in this area and report on them in the future Legal News.