- A group needs to confirm that a Ukrainian counterparty is not sanctioned or owned by a sanctioned person.
- A bank has queried the ultimate beneficial owner recorded in the register.
- An activity has commenced without the licence it required.
- A whistleblower report requires independent investigation.
- Ukrainian operations need to be brought within the group's global compliance framework.
Overview
International companies operating in Ukraine face a compliance environment shaped by several overlapping regimes: Ukrainian financial monitoring rules, the sanctions programmes of Ukraine, the EU, the UK and the US, beneficial ownership transparency requirements, sector licensing and data protection. Each has its own logic, and a control framework designed for one will not satisfy the others.
We help companies establish what actually applies to them, build proportionate controls, and respond when something has gone wrong. Our work is practical: policies that operating teams can follow, screening that catches what matters, and remediation that closes an issue rather than documenting it.
Typical situations
Scope of work
What we do
The matters we handle within this practice. Engagements are usually a combination of several of them rather than a single item.
01
Sanctions
Screening of counterparties, owners and supply chains against Ukrainian, EU, UK and US lists, and advice on permissible dealings and licence applications.
02
Anti-money laundering
Financial monitoring obligations for regulated entities, customer due diligence procedures and reporting.
03
Beneficial ownership
Ownership structure filings, annual confirmation and correction of incorrect register entries.
04
Licensing
Identification of activities requiring a licence or permit, application preparation and maintenance of licence conditions.
05
Data protection
Personal data handling under Ukrainian law and, where relevant, GDPR alignment for cross-border processing.
06
Anti-corruption
Policies, third-party due diligence and gift and hospitality controls aligned with the UK Bribery Act and FCPA.
07
Internal investigations
Confidential investigation of suspected misconduct, with findings structured for the board and, where required, for regulators.
08
Regulatory engagement
Correspondence, inspections and dealings with Ukrainian regulators, including responses to information requests.
How we work
From first call to completion
A predictable sequence with a written output at each stage, so that you always know the position and what it will cost to reach the next one.
01
Assessment
We identify which regimes apply and where the current arrangements fall short.
02
Design
Policies, screening procedures and controls proportionate to the actual risk, not a generic template.
03
Implementation
Filings made, licences obtained, training delivered and responsibilities allocated.
04
Monitoring
Periodic review, updated screening and support when an issue arises.
Why clients instruct us
Local knowledge, international standards
We work the way our clients' in-house teams and international counsel expect: clear scope, written advice, English-language reporting and no surprises on fees.
- Advice in English, drafted to be usable by a board that does not know Ukrainian law.
- Fee estimates agreed before work begins, with fixed fees where the scope allows.
- A named partner responsible for the matter, not a rotating team.
- Practising in Ukraine since 2003, through every regulatory cycle since.
Questions
Frequently asked
How do we check whether a Ukrainian counterparty is sanctioned?
Screening must cover the entity, its beneficial owners and its directors, against Ukrainian, EU, UK, US and other applicable lists, and must apply ownership and control tests rather than name matching alone. An entity may be restricted because a listed person holds an interest in it even though the entity itself is not named.
Who must file beneficial ownership information?
Ukrainian legal entities must record and maintain their ownership structure and ultimate beneficial owners in the state register, confirm the information annually and update it when it changes. Foreign-owned entities frequently miss the annual confirmation, which carries a fine on the director personally.
Does GDPR apply to our Ukrainian entity?
It can, where the entity processes personal data of individuals in the EU in the context of offering goods or services or monitoring behaviour. Ukrainian data protection law applies independently. Where both apply, we align a single set of controls to the higher standard rather than maintaining two regimes.
What triggers a licence requirement?
Ukrainian law lists the activities subject to licensing — they include certain financial, medical, educational, security, transport and energy activities. The classification depends on what the business actually does rather than how it is described in its charter, and operating without a required licence exposes the company to fines and the transaction to invalidity.
Related
Practices that usually come with this one
06
Banking & Accounts
For a foreign-owned Ukrainian company, opening a bank account is usually harder than incorporation. The obstacle is ra…
Read more →08Due Diligence
Due diligence is not a document-collection exercise. It is the process of establishing what you are actually buying an…
Read more →05Antitrust & Competition
Ukrainian merger control catches more transactions than foreign parties expect, and the penalty for closing without cl…
Read more →04Taxes & Finance
Tax rarely determines whether an investment happens, but it routinely determines what it returns. We advise on the tax…
Read more →
Next step
Discuss your matter with us
Tell us what you need to achieve in Ukraine. The first consultation is free and confidential — we will tell you candidly whether we are the right firm for the task.