Analysis of the impact of sanctions on the operations of extractive companies

A year has passed since the entry into force of legislative amendments to the Subsoil Code of Ukraine (hereinafter referred to as the Subsoil Code, the Code) introduced by the Law of Ukraine "On Amendments to Certain Legislative Acts of Ukraine on Improving Legislation in the Sphere of Subsoil Use" (hereinafter referred to as the Law).

In accordance with these amendments, the State Geology and Subsoil Service of Ukraine (SGS) cancels/suspenses the special permit for subsoil use of users whose ultimate beneficial owners (UBOs) have been subject to a sanction provided for in Clause 6 of Part 1 of Article 4 of the Law of Ukraine "On Sanctions" (cancellation or suspension of licenses and other permits).

The SGS suspended the validity of 25 special permits for 21 companies whose UBOs have been subject to sanctions.