Sanctions Instead of Justice: Now NABU Also Wants to Use This Tool

On March 23, 2026, the National Anti-Corruption Bureau (NABU) publicly appealed to the President and the SBU with a request to impose sanctions against former MP from the "Party of Regions" Yuriy Ivanyushchenko — "Yura Yenakiievskyi." NABU refers to the suspect's persistent financial ties with Russia: companies that paid taxes to the Russian budget, a Russian federation passport, and contacts with individuals involved in financing armed formations.

This is the first time NABU has requested the use of an extrajudicial method to block the assets of Ukrainian citizens. The reason: the failure of the prosecution in courts. This is a very disturbing trend, as previously the state often resorted to such actions when there was a lack of evidence.

looked into the problem of sanctions that substitute for the court, whether there is systematicity, and what the logic is behind whom the state decides to punish with sanctions.

Why NABU cannot legally extradite Ivanyushchenko from Monaco

In September 2025, NABU put Yuriy Ivanyushchenko on the wanted list on suspicion of legalizing 18 hectares of land worth 160 million UAH, and in October 2025, the HACC (Higher Anti-Corruption Court) arrested ex-MP Ivanyushchenko in absentia. However, the appellate chamber overturned the arrest due to a violation of the suspicion service procedure — the defense proved that NABU had not served the suspicion to Ivanyushchenko.

In March 2026, NABU and SAPO (Specialized Anti-Corruption Prosecutor's Office) filed a new motion for arrest. On March 19, the court denied it again. The defense argued that Ivanyushchenko is not hiding in the Russian Federation or in occupied territories, as his addresses in Monaco and France were known to law enforcement from Swiss legal assistance documents, and his Bulgarian passport records no entry into Russia. The prosecution tried to prove residency in the Russian Federation using a 2019 messenger message from a third party, which was later entirely denied. Another "evidence" confirming Ivanyushchenko's Russian citizenship was a screenshot from a WhatsApp correspondence, which a NABU detective called an "individual Interpol report." The National Central Bureau of Interpol in Ukraine, however, replied that no such document exists in their databases. The court found NABU's evidence unconvincing and denied the arrest of Yuriy Ivanyushchenko.

This is not the first time Ivanyushchenko has avoided arrest. In 2019, the seizure of Ivanyushchenko's property was lifted, and the proceedings against him regarding the attempted raider takeover of the "7th Kilometer" market were closed by the Odesa Prosecutor's Office. Later, the Prosecutor General's Office reopened the proceedings. On March 20, 2026, regarding this lifting of the property seizure, searches were conducted at the Kyiv Court of Appeal and the Office of the Prosecutor General. According to sources, the investigation is checking how judges and prosecutors overturned the seizure of Ivanyushchenko's funds in Switzerland in 2019. This involves over 70 million euros.

In other words, in 2019 the prosecutor's office "helped" lift the seizures, and in 2026 it "could not" return them. The application of sanctions in this case could become an extrajudicial mechanism for blocking assets while the prosecution looks for ways to strengthen its position in court. But, regardless of the goal, this method does not become more legal.

NSDC Sanctions: Without Sufficient Evidence and Obvious Criteria

In recent years, NSDC (National Security and Defense Council) sanctions have turned into a regular way for the state to react to suspicions of cooperation with Russia, economic ties, or information activities. However, an analysis of decisions from 2024-2026 shows: despite a common procedure, these decisions cover different categories of people and do not demonstrate a unified standard of application.

For example, by presidential decree No. 38/2025 of January 19, 2025, restrictive measures were introduced against 18 persons "connected with Russia." Among them are MPs Yuriy Boyko and Nestor Shufrych, ex-MPs Yevgeniy Murayev, Oleg Voloshyn, the leader of the banned CPU Petro Symonenko, journalist of the banned "Strana" Svitlana Kryukova, businessman Kostyantyn Grygoryshyn with assets in Ukraine and the Russian Federation, actress Ruzhena Rublova, and others. Obviously, the nature of their ties with the Russian Federation varies.

Sanctions are uneven even within a single decree. Shufrych, suspected of high treason and financing the Rosgvardiya to guard his own real estate in Crimea, received 21 sanctions. His "OPZZh" associate Boyko received only one indefinite sanction: deprivation of state awards. Murayev, Voloshyn, and Symonenko received a full package of economic restrictions, but for 10 years.

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Sanctions were also imposed on a number of pro-Russian media figures: blogger Oleksandr Shelest, political scientist Vadym Karasyov, former advisor to the Presidential Office Oleksiy Arestovych, Kyrylo Bondarenko, and Myroslav Oleshko. However, none of them were detained while they were in Ukraine and there was an opportunity to bring them to criminal responsibility. And Svitlana Kryukova continues her activities in Ukraine even now.

The explanation of sanctions as a "threat to state security and an obstacle to economic development" is also quite vague. It can include:

capital outflow;
financing of terrorism (business in occupied territories);
high treason;
"business ties with the Russian Federation."

The threat can even be imaginary. Thus, according to the Ministry of Justice's explanation, sanctions against Petro Poroshenko "are of a preventive nature to prohibit him from performing actions that could harm national interests."

Based on such "security-economic" grounds, on February 12, 2025 (Decree No. 81/2025), sanctions were introduced against five individuals: Ihor Kolomoisky, Kostyantyn Zhevago, Hennadiy Boholyubov, Viktor Medvedchuk, and the fifth president Petro Poroshenko. All are indefinite. Yet, regarding Volodymyr Zelenskyy's partner from "95 Quarter," Timur Mindich, who is suspected of embezzling hundreds of millions of UAH in budget funds at "Energoatom," the President somehow introduced sanctions for only three years.

In one of his interviews, Volodymyr Zelenskyy directly stated that the NSDC is his weapon and he uses it because "it is faster than following the law."

What Human Rights Defenders Say and Why the EU Does Not Recognize These Sanctions

In February 2025, the Kharkiv Human Rights Group, the Ukrainian Helsinki Human Rights Union, and the Center for Civil Liberties published a joint statement criticizing the practice of applying sanctions against Ukrainian citizens. In their view, such restrictions contradict the Constitution as they involve the limitation of rights and freedoms without a court decision.

According to the Supreme Court, since 2017, more than 460 cases have been opened in Ukraine to challenge sanctions. Only one of them has been granted.

The problem also extends beyond Ukrainian law. In October 2025, the ECHR (European Court of Human Rights) recognized the NSDC sanctions as illegal and established a violation of the Convention for the Protection of Human Rights. The court noted that sanctioned persons in Ukraine do not have sufficient procedural guarantees to protect their rights during judicial review of sanction decisions, and the NSDC decision lacks individual justification.

NSDC sanctions are also not recognized in EU jurisdictions: there they are viewed rather as political-legal decisions with elements of political pressure, rather than an international legal instrument. This means that a person whose assets are blocked in Ukraine may well keep them in a European jurisdiction — where the Ukrainian sanction decision has no legal force.

The criteria for applying sanctions often remain non-obvious, and the effectiveness of the extrajudicial mechanism in achieving a specific legal or economic result remains an open question.