Members of the Committee of Verkhovna Rada of Ukraine on Anti-corruption Policy,taking into account the start of full-scale military aggression of Russian Federation against Ukraine on 24/02/2022,
considering UN General Assembly Resolution A/RES/ES-11/1 “Aggression against Ukraine” adopted on March, 2, 2022,
bearing in mind numerous violations of UN Charter, international humanitarian law, human rights violations on the territory of Ukraine by Russian Federation,
understanding the necessity to bring aggressor maximal damages caused by the started military aggression, undermine its capacity to continue military aggression against Ukraine,
for the sake of response to the military aggression of Russian Federation, ensuring national security of Ukraine, elimination of threats for Ukrainian independence and territorial integrity,
decided to address this letter to the Council of European Union, European External Affairs Service, the US Treasury, the UK Foreign, Commonwealth and Development Office, Switzerland's Federal Council, parliaments and governments of foreign states on introduction of comprehensive and effective restrictive measures (sanctions) against Russian Federation.
Based on above-mentioned, we sincerely ask you to introduce the following restrictive measures (sanctions) against Russian Federation:
1) to expand list of Russian and Belarusian banks, to which provision of specialised financial messaging services, which are used to exchange financial data (SWIFT) is prohibited, in order to fully cover Russian and Belarusian banking system without any exceptions;
2) to expand the list of legal entities under the special restrictive economic and other measures (sanctions) to cover all the Russian and Belarusian state-owned enterprises, including “Gazprom”, “Rosneft”, “Rosatom”, “RZhD” (“Russian Railways”), “Roskosmos” and their subsidiaries, legal entities with shares owned by above-mentioned companies; to prohibit introduction of joint enterprises with such companies and implantation of any joint projects with such companies (including those that have been already started), to ban such companies from participation in public procurements;
3) to introduce prohibition for take-offs, landings and flights over the territory of states for aircrafts owned, used or disposed by Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
4) to introduce prohibition for enters to the ports and territorial waters of states for vessels owned, used or disposed by Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
5) to introduce prohibition for railway transportations to and from Russian Federation and Republic of Belarus;
6) to introduce personal special restrictive measures that include prohibition to travel, ban for any financial operations, ban for acquisition, disposal or sale of any assets for the following categories:
(a) high-level political leadership of Russian Federation and Republic of Belarus;
(b) members of parliaments of Russian Federation and Republic of Belarus;
(c) businessmen with significant financial resources in Russian Federation and Republic of Belarus (including top-100 Russian oligarchs);
(d) persons that undertake any action in order to conduct, enable, facilitate, legitimize military aggression of Russian Federation against Ukraine, establish threats for Ukrainian statehood and national security, territorial integrity of Ukraine;
7) to introduce the same personal special restrictive measures for family members of persons mentioned in para. 6 above of the same scope of restrictions;
8) to introduce a requirement for immediate leave of foreign states by persons under the personal special restrictive measures;
9) to immediately freeze all the assets that are owned and/or disposed by natural or legal persons, for which/whom personal special restrictive measures (sanctions) are required, legal entities under the direct or indirect ownership of Russian and Belarusian governments, afterwards to forfeit such assets and to sell them subsequently; these measures should be applied to virtual assets, including cryptocurrencies;
10) to prohibit persons under the personal special restrictive measures (sanctions) to acquire foreign citizenship in exchange for investments in foreign states (so-called “golden passports”), as well as to deprive of citizenship acquired before based on such a ground;
11) to introduce prohibition for transactions and operations in MasterCard, Visa, American Express payment systems in Russian Federation and Republic of Belarus and/or for any operations with the following parties: Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
12) to include Russian Federation and Republic of Belarus to the FATF list of high-risk jurisdictions;
13) to introduce a prohibition for disposal or use of SDR issued by the IMF for Russian Federation and Republic of Belarus and to distribute these SDR to Ukraine;
14) to exclude or to suspend membership of Russian Federation and Republic of Belarus in international financial institutions, including EBRD, IBRD, as well as to prohibit allocation of any funds to these states from international financial institutions;
15) to introduce a prohibition for any investment funds (including pension funds) to directly or indirectly invest to legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
16) to introduce a prohibition for any direct or indirect financing (including though loans, lending, refundable or non-refundable financial assistance) for legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
17) to introduce a prohibition for provision of insurance services (including insurance for assets, vehicles, risks etc.) for Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
18) to introduce a prohibition for provision of auditing services by so-called “Big Four” companies for legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
19) to introduce a prohibition for opening and maintaining bank accounts for Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus; to close existing accounts; to limit cash withdrawals to equivalent of USD 2,000;
20) to introduce a prohibition for issuance of business, study and tourist visa for Russian and Belarusian citizens;
21) to introduce a prohibition of international trade operations with Russian Federation and Republic of Belarus: to ban import of gas and oil and products of their subsequent processing; to ban export of military technologies and dual-use items; to prohibit export of chemicals, cosmetics, seeds, pharmacy products, foods and beverages, all the electronics and semiconductors, software (including updates for software and withdrawal of licenses for previously sold software), machinery products, cars and vehicles, luxury goods;
22) to introduce a prohibition for functioning in Russian Federation and Republic of Belarus of Google, Google Playmarket, Apple Store, Amazon Web Services platforms as well as all the digital cloud services;
23) to introduce a prohibition for broadcasting and any king of spreading the information (including on Youtube, Facebook and other platforms) for TV-channels and information agencies, which are directly or indirectly controlled by Russian and Belarusian governments, as well as for propagandists who systemically spread pro-Russian propaganda and disinformation;
24) to ensure full and comprehensive compliance with sanctions regime by all the states, including through the application of “secondary” sanctions for those persons and entities who violates sanctions regime;
25) to ensure transparency of ownership of legal entities, including disclosure of beneficial ownership, in order to provide effective control on compliance with sanctions regime, inter alia, for legal entities registered in so-called “tax havens”;
26) to limit possibilities for establishment and registration of new legal entities for Russian and Belarusian citizens as well as for third persons acting on their behalf;
27) to introduce a prohibition on management of corporate rights and shares (“bearer shares”) owned by Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
28) to maintain sanctions regime till the end of military aggression of Russian Federation against Ukraine and restoration of territorial integrity of Ukraine within internationally recognized borders (i.e., with restoration of full effective control over temporary occupied territories of Donetsk and Luhanks regions, Autonomous Republic of Crimea).
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considering UN General Assembly Resolution A/RES/ES-11/1 “Aggression against Ukraine” adopted on March, 2, 2022,
bearing in mind numerous violations of UN Charter, international humanitarian law, human rights violations on the territory of Ukraine by Russian Federation,
understanding the necessity to bring aggressor maximal damages caused by the started military aggression, undermine its capacity to continue military aggression against Ukraine,
for the sake of response to the military aggression of Russian Federation, ensuring national security of Ukraine, elimination of threats for Ukrainian independence and territorial integrity,
decided to address this letter to the Council of European Union, European External Affairs Service, the US Treasury, the UK Foreign, Commonwealth and Development Office, Switzerland's Federal Council, parliaments and governments of foreign states on introduction of comprehensive and effective restrictive measures (sanctions) against Russian Federation.
Based on above-mentioned, we sincerely ask you to introduce the following restrictive measures (sanctions) against Russian Federation:
1) to expand list of Russian and Belarusian banks, to which provision of specialised financial messaging services, which are used to exchange financial data (SWIFT) is prohibited, in order to fully cover Russian and Belarusian banking system without any exceptions;
2) to expand the list of legal entities under the special restrictive economic and other measures (sanctions) to cover all the Russian and Belarusian state-owned enterprises, including “Gazprom”, “Rosneft”, “Rosatom”, “RZhD” (“Russian Railways”), “Roskosmos” and their subsidiaries, legal entities with shares owned by above-mentioned companies; to prohibit introduction of joint enterprises with such companies and implantation of any joint projects with such companies (including those that have been already started), to ban such companies from participation in public procurements;
3) to introduce prohibition for take-offs, landings and flights over the territory of states for aircrafts owned, used or disposed by Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
4) to introduce prohibition for enters to the ports and territorial waters of states for vessels owned, used or disposed by Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
5) to introduce prohibition for railway transportations to and from Russian Federation and Republic of Belarus;
6) to introduce personal special restrictive measures that include prohibition to travel, ban for any financial operations, ban for acquisition, disposal or sale of any assets for the following categories:
(a) high-level political leadership of Russian Federation and Republic of Belarus;
(b) members of parliaments of Russian Federation and Republic of Belarus;
(c) businessmen with significant financial resources in Russian Federation and Republic of Belarus (including top-100 Russian oligarchs);
(d) persons that undertake any action in order to conduct, enable, facilitate, legitimize military aggression of Russian Federation against Ukraine, establish threats for Ukrainian statehood and national security, territorial integrity of Ukraine;
7) to introduce the same personal special restrictive measures for family members of persons mentioned in para. 6 above of the same scope of restrictions;
8) to introduce a requirement for immediate leave of foreign states by persons under the personal special restrictive measures;
9) to immediately freeze all the assets that are owned and/or disposed by natural or legal persons, for which/whom personal special restrictive measures (sanctions) are required, legal entities under the direct or indirect ownership of Russian and Belarusian governments, afterwards to forfeit such assets and to sell them subsequently; these measures should be applied to virtual assets, including cryptocurrencies;
10) to prohibit persons under the personal special restrictive measures (sanctions) to acquire foreign citizenship in exchange for investments in foreign states (so-called “golden passports”), as well as to deprive of citizenship acquired before based on such a ground;
11) to introduce prohibition for transactions and operations in MasterCard, Visa, American Express payment systems in Russian Federation and Republic of Belarus and/or for any operations with the following parties: Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
12) to include Russian Federation and Republic of Belarus to the FATF list of high-risk jurisdictions;
13) to introduce a prohibition for disposal or use of SDR issued by the IMF for Russian Federation and Republic of Belarus and to distribute these SDR to Ukraine;
14) to exclude or to suspend membership of Russian Federation and Republic of Belarus in international financial institutions, including EBRD, IBRD, as well as to prohibit allocation of any funds to these states from international financial institutions;
15) to introduce a prohibition for any investment funds (including pension funds) to directly or indirectly invest to legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
16) to introduce a prohibition for any direct or indirect financing (including though loans, lending, refundable or non-refundable financial assistance) for legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
17) to introduce a prohibition for provision of insurance services (including insurance for assets, vehicles, risks etc.) for Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
18) to introduce a prohibition for provision of auditing services by so-called “Big Four” companies for legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
19) to introduce a prohibition for opening and maintaining bank accounts for Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus; to close existing accounts; to limit cash withdrawals to equivalent of USD 2,000;
20) to introduce a prohibition for issuance of business, study and tourist visa for Russian and Belarusian citizens;
21) to introduce a prohibition of international trade operations with Russian Federation and Republic of Belarus: to ban import of gas and oil and products of their subsequent processing; to ban export of military technologies and dual-use items; to prohibit export of chemicals, cosmetics, seeds, pharmacy products, foods and beverages, all the electronics and semiconductors, software (including updates for software and withdrawal of licenses for previously sold software), machinery products, cars and vehicles, luxury goods;
22) to introduce a prohibition for functioning in Russian Federation and Republic of Belarus of Google, Google Playmarket, Apple Store, Amazon Web Services platforms as well as all the digital cloud services;
23) to introduce a prohibition for broadcasting and any king of spreading the information (including on Youtube, Facebook and other platforms) for TV-channels and information agencies, which are directly or indirectly controlled by Russian and Belarusian governments, as well as for propagandists who systemically spread pro-Russian propaganda and disinformation;
24) to ensure full and comprehensive compliance with sanctions regime by all the states, including through the application of “secondary” sanctions for those persons and entities who violates sanctions regime;
25) to ensure transparency of ownership of legal entities, including disclosure of beneficial ownership, in order to provide effective control on compliance with sanctions regime, inter alia, for legal entities registered in so-called “tax havens”;
26) to limit possibilities for establishment and registration of new legal entities for Russian and Belarusian citizens as well as for third persons acting on their behalf;
27) to introduce a prohibition on management of corporate rights and shares (“bearer shares”) owned by Russian or Belarusian citizens, legal entities registered in Russian Federation or Republic of Belarus, legal entities registered in other states with beneficial ownership of Russian or Belarusian citizens and/or with the majority of shares directly or indirectly owned by Russian or Belarusian citizens or legal entities registered in Russian Federation or Republic of Belarus;
28) to maintain sanctions regime till the end of military aggression of Russian Federation against Ukraine and restoration of territorial integrity of Ukraine within internationally recognized borders (i.e., with restoration of full effective control over temporary occupied territories of Donetsk and Luhanks regions, Autonomous Republic of Crimea).
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