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29 June 2022

Ukraine's President creates a register of oligarchs, as mandated by a 2021 law on persons with major political and economic sway in public life (oligarchs). Ukraine’s National Security and Defense Council (NSDC), an advisory body under the President, can now proceed with designating oligarchs to be included in the register.

The register, set up by a presidential decree of 29 June 2022, is the means of identifying those meeting the definition of oligarchs under the law “On the Prevention of National Security Risks Related to Excessive Influence of Persons Holding Significant Economic and Political Weight in Public Life (Oligarchs)”. The law targets individuals deemed capable of adversely affecting the nation’s political life due, in particular, to their control of major economic wealth and involvement in politics.

One legally becomes an oligarch once entered into the register. That is done by a decision of the NSDC, pursuant to proposals made by the Cabinet of Ministers and the various law enforcement and security services. Since the NSDC is chaired by the President, it appears that it is he who will have a final say in the matter. 

In addition to an oligarch’s personal details and the relevant NSDC decision, the register will contain a justification for the person’s oligarch status as formulated by the NSDC and information on his disclosed contacts with public officials. 

The register will be run by a special department of the NSDC. It can also be operated as part of some other public register.

Access to full information in the register is to be limited to specified officials and governmental agencies. The general public might have access to the register’s rump version, setting out more basic information.

By way of background, the law treats as oligarchs individuals showing at least three of the four characteristics:

  • involvement in political life (by holding a specified public office),involvement in political

  • exercising important influence on mass media,

  • controlling a particular kind of business monopoly (including a natural one), and

  • holding at least UAH 2.3 billion in assets.

Under the law, oligarchs may not finance political parties and buy assets in large-scale privatizations. The law also seeks to control their contacts with civil servants and public officials. These must report their interactions with oligarchs by filing special declarations.

As the Constitution of Ukraine guarantees equal treatment for all, those branded as oligarchs may feel like being singled out for special – and potentially unfair – treatment. Yet no constitutional challenges against the law seem to have been brought so far. In any event, a decision to designate one as an oligarch may always be contested in court under the normal administrative law procedures. Whatever the legal position, however, some may still find it more profitable to shed unhelpful assets to sidestep being labelled an oligarch.

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