On 23 January 2026, the Cabinet of Ministers of Ukraine submitted Draft Law No. 14396 to the Verkhovna Rada of Ukraine, proposing amendments to the Customs Code of Ukraine aimed at regulating the procedure for the implementation of sanctions by customs authorities.
The draft law provides for the establishment of specific powers of customs authorities to enforce sanctions applied in accordance with the Law of Ukraine “On Sanctions”, considering data from the State Sanctions Register and through electronic information exchange with other state registers.
The key mechanisms for the implementation of sanctions include:
- refusal to carry out customs clearance, release, or transit of goods and commercial vehicles;
- suspension or non-refund of advance payments and overpaid customs duties;
- suspension or revocation of permits, authorisations, and guarantees required for conducting business activities.
The sanction in the form of confiscation of assets in favour of the state will be implemented by customs authorities exclusively on the basis of a court decision that has entered into legal force. Decisions of customs authorities adopted during sanction enforcement may be challenged only through court proceedings.
In the event the amendments are adopted, participants in foreign economic activity are advised to:
- verify the company, its counterparties, and beneficial owners in the State Sanctions Register prior to customs clearance;
- update information on ownership structure and ultimate beneficial owners;
- assess the risks of suspension of permits, authorisations, and customs procedures;
- take into account that challenges to decisions of customs authorities are possible exclusively in court.
We will continue to closely monitor further developments in this area and report on them in the future Legal News.
![Law Firm Logo](https://sdm-partners.com/wp-content/uploads/2023/09/sdm-bot-logo.png"){kind=logo}