Ukraine sanctions 41 entities owning 56 vessels for illegal grain exports from occupied ports (Presidential Decree No. 860/2025)

Mechanism

Decree No. 860/2025 ratifies an NSDC resolution designating 41 legal entities that between them own 56 maritime vessels identified as having called at the closed, Russian-occupied Ukrainian ports of Sevastopol and Feodosia to load wheat, sunflower seeds, and other food commodities for export abroad. Ukrainian and Ukrainian-government-linked reporting (Ukrinform; the President's Office representation for Crimea) states 17 of the 56 vessels sail under flags other than Russia's, and that Ukraine intends to approach the relevant flag-state governments to press them to stop issuing permits/licences to the designated vessels. GTA's own country-coverage tag for this intervention names Comoros, Cyprus, and Georgia among the affected (non-Russian) flag states; the full flag-state breakdown was not independently re-derived for this filing. The designation carries the standard NSDC-decree sanctions toolkit under Ukraine's 2014 Law on Sanctions: asset blocking, a bar on commercial transactions and investment instruments, transit/resource-transit restrictions, and foreign-customer limitations, applied here for a 10-year term. As with the adjacent 870/2025 and 871/2025 tranches filed the same week, the presidential website itself blocked automated access for this filing; the Rada legal-portal mirror confirms the decree's existence, number, date, and 27 November 2025 entry-into-force date but not the full 56-vessel/41-entity annex.

Downstream implications

• Extends Ukraine's autonomous sanctions architecture into the maritime/

shipping layer specifically tied to occupied-territory resource extraction, complementing existing Ukraine, EU, US, and Swiss sanctions against much of the same shadow-fleet vessel population (per Ukrainian reporting, a significant share of the 56 vessels were already sanctioned by other jurisdictions).

• Targets the agricultural-export leg of the broader "stolen goods from

occupied territory" enforcement effort, parallel to Ukraine's existing sanctions on occupied-Crimea/Donbas mineral and industrial extraction.

• Adds pressure on third-country flag registries (Comoros, Cyprus,

Georgia named) to deny or revoke registration/licensing for the designated vessels, a lever aimed at raising the compliance cost of operating in the occupied-port grain trade.

Open questions

• The full 41-entity/56-vessel annex was not confirmed from public

sources during this filing; follow-up should check Ukraine's State Register of Sanctions (drs.nsdc.gov.ua/actions) once accessible for entity-level detail and the complete flag-state list.

• Extent of overlap between this designee list and existing EU/US/UK/CH

shadow-fleet or Crimea-related sanctions lists is unconfirmed.