On September 13, 2026, Ukrainian President Volodymyr Zelensky signed Decree No. 899/2026, putting into force a National Security and Defense Council (NSDC) decision of September 8, 2026 that imposes personal special economic and restrictive measures (sanctions) on 29 individuals and 29 legal entities. The decree, enacted under Article 107 of the Constitution and Article 5 of the Law of Ukraine "On Sanctions", took effect immediately on publication. The designated legal entities are enterprises linked to Russia's Rostec state defense corporation, together with dual-use and Kalashnikov-linked producers.
For compliance teams, the operative consequence is immediate. Every counterparty, client and transaction touching Ukrainian jurisdiction must be rescreened against the updated national sanctions list, and any asset freeze or transaction prohibition must be applied now, without waiting for parallel EU or US designations. The decree is one of three sanctions instruments published the same day, each with a distinct target set, and each must be screened independently.
Who is designated under Decree 899/2026?
The NSDC decision designates two groups, set out in two annexes appended to the decree. Annex 1 lists 29 individuals subject to personal special economic and restrictive measures. Annex 2 lists 29 legal entities, identified by the presidential press service as enterprises of the Rostec corporation, alongside dual-use and Kalashnikov-linked producers. The designation proposals were prepared and submitted by the Security Service of Ukraine (SBU) and adopted by the NSDC on September 8, 2026, then enacted by presidential decree five days later.
What obligations does the decree create, and for whom?
The measures bind Ukrainian persons and any entity operating under Ukrainian law or through Ukrainian financial infrastructure. The decree assigns implementation and effectiveness monitoring to the Cabinet of Ministers and the SBU, acting together with the National Bank of Ukraine (NBU) and the Commission of State Awards and Heraldry.
For NBU-supervised banks, that means immediate list ingestion, counterparty screening and asset blocking against the 58 new designations. For dual-use and electronics exporters, it means export-control screening against the newly listed entities. For international screening desks that ingest Ukraine's national list as part of their consolidated sanctions data, the 58 designations must be loaded and applied to existing client portfolios and pending transactions.
How does Decree 899/2026 relate to the other two decrees?
Decree 899/2026 was published alongside two further sanctions decrees on September 13, 2026. Each is a separate instrument with a distinct NSDC decision date and target set. This article covers 899/2026; the others are screened independently.
| Decree | NSDC decision date | Target set |
|---|---|---|
| 899/2026 | September 8, 2026 | 29 individuals + 29 Rostec-linked legal entities |
| 900/2026 | September 7, 2026 | 20 Russian shadow-fleet vessels |
| 901/2026 | September 13, 2026 | Propagandists and media figures |
Will the EU or US adopt equivalent measures?
The decree instructs the Ministry of Foreign Affairs of Ukraine to inform the European Union, the United States and other states of the designations and to raise the question of adopting analogous restrictive measures. This is the standard Ukrainian mechanism for seeking external alignment, but it creates no obligation on EU or US operators until those jurisdictions act. Firms should treat the Ukrainian list as operative now and monitor for mirror designations in the EU consolidated list, the US SDN list and the UK sanctions list.
Continuous, per-jurisdiction monitoring surfaces national sanctions designations like Decree 899/2026 the moment they publish, before mirror listings appear in other jurisdictions.
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Compliance teams should now verify whether any counterparty, client or pending transaction matches the 58 designations in Decree 899/2026, apply asset freezes and transaction prohibitions under the Law of Ukraine "On Sanctions", update internal screening lists and NBU reporting workflows, and brief relationship managers on the Rostec and dual-use nexus. Treat the decree as live from September 13, 2026 and watch for EU, US and UK mirror designations in the coming weeks.
