March 2026
Ukraine Sanctions & Control Definition
Information
Investing in Ukraine’s capital markets now requires much stricter oversight. Recent regulatory updates have significantly raised the stakes for reporting substantial shareholdings, introducing massive new fines and a broader definition of who counts as a “controlled” entity.
1. Massive Increases in Fines (Starting 2026)
While missing a disclosure deadline isn’t a criminal offense, the financial penalties are shifting from “minor” to “business-threatening.” Starting January 1, 2026, the Securities Commission (SC) will apply an escalating scale to fines.
| Year | Multiplier | Max Fine (Individual) | Max Fine (Legal Entity) |
| Current | N/A | UAH 85,000 | UAH 85,000 |
| 2026 | 0.2 | UAH 4.4 Million | UAH 22 Million |
| 2029 | 0.8 | UAH 17.6 Million | UAH 88 Million |
| Full | 1.0 | UAH 22 Million | UAH 110 Million* |
*Legal entity fines are capped at 5% of annual turnover.
Beyond Fines: The SC can also issue public warnings or strip you of your voting rights for the shares in question.
2. New Definition of “Control”
You must aggregate (add together) your own shares with those held by any “controlled undertaking.” Under the new rules, control is defined as having decisive influence over a business.
This influence exists if you:
Hold or use a major portion of the company’s assets.
Can dictate management decisions or voting outcomes.
Have contracts that allow you to give binding instructions.
Hold key management or board positions across multiple entities.
3. “Related Parties” and Your Responsibility
The definition of a “controlled” entity now explicitly includes family members (spouses, parents, children, siblings) if they conduct business together or in “concert.”
Crucial Note: Identifying these related parties and calculating the total shares is entirely your responsibility. The regulator expects you to conduct a thorough internal audit to ensure every “decisive influence” is accounted for in your reports.
Our Thoughts
The grace period for low-cost errors is ending. To avoid the escalating penalty “multipliers” starting in 2026, you must re-evaluate your corporate structure and family business ties today.
To learn more about Artius Global and its solutions, please contact enquiries@artiusglobal.com.
The above content is purely for information and does not purport to offer legal or professional counsel.