User-friendly, up-to-date, and on-the-fly: The State Register of Sanctions created without additional budgetary funds

The State Register of Sanctions was created by the Information Technology Service of the NSDC Office without attracting additional budgetary funds. This was emphasised in an interview with Army FM by Mykola Dobysh, Acting Head of the Information Technology Service of the NSDC Office. He noted that the introduction of the Register improves the state sanctions policy and the availability of information on sanctioned entities.

Free up-to-date information on sanctioned entities

• Mykola, please tell us in more detail how the State Register of Sanctions works and what its main purpose is.
• The purpose of the register is to provide free access to the up-to-date and verified information on sanctioned entities. As of 14 February 2024, the Register includes 17,202 individuals and legal entities.
• As for the work of the State Register of Sanctions, let's start with the sanctions mechanism in our country. According to the Law of Ukraine “On Sanctions”, the President of Ukraine, the Verkhovna Rada of Ukraine, the Cabinet of Ministers of Ukraine, the Security Service of Ukraine, and the National Bank of Ukraine are the subjects of proposals for imposing sanctions. They submit their proposals to the NSDC Office. Then our state experts prepare a package of documents and submit it to the Council members for a vote. Based on the results of the vote, a draft Decree of the President of Ukraine is prepared. Only once it is signed, sanctions against individuals or legal entities are enacted.
• How often is the information in the State Register of Sanctions updated?
• The Register is updated synchronously with the publication of the Decrees of the President of Ukraine. There is one day to enter the data after the Presidential Decree comes into force. But we try to do it as quickly as possible.

During the first week of operation, the State Register of Sanctions received 2 million requests

• How many requests have been received by the register so far?
• During the first week of its operation, the State Register of Sanctions received 2 million requests from 32,500 unique users. In total, about 50,000 electronic extracts from the Register were generated.
• For the first seven days of operation, these are big numbers that impressed us. We hope that our service will continue to be useful to government agencies, private companies, and anyone concerned with and those implementing the state’s sanctions policy.
• Does the Register apply to both Ukrainian sanctioned entities and russian occupying criminals, and a number of other people subject to Ukrainian sanctions?
• If we take a broad view of sanctions policy, we can distinguish between personal sanctions, sectoral sanctions and court decisions. Personal sanctions can be imposed on stateless persons, criminals, and terrorist organisations. Sectoral sanctions are imposed on certain types of activities in a particular country. There are also court rulings that allow certain assets of sanctioned entities to be collected as state revenue.

There are plans to integrate with partner countries on sanctions lists

• Mykola, can you tell us whether the State Register of Sanctions is integrated with European or American structures?
• The State Register of Sanctions is available in English. We inform the embassies of our partner countries that we have launched the Register and that it is possible to connect to it automatically or access it through a public interface.
• I would like to note that we have already received requests to connect to the Register not only from the governments of our partner countries, but also from large international organisations. For example, SWIFT, an international financial company that makes bank transfers, is currently connecting to the Register. In the future, we are going to integrate with our partner countries to create sanctions lists that will be available in the Register interface.
• In general, for the sake of convenience and efficiency, we will expand the functionality and not stop at what we have.
• Thank you for the substantive conversation.