Ukraine sanctions 35 entities and 42 individuals in Russia, Kyrgyzstan and UAE over A7 crypto-network sanctions circumvention (Presidential Decree No. 103/2026)

Mechanism

Decree No. 103/2026 ratifies a second NSDC sanctions tranche signed the same day as Decree No. 102/2026 (27 entities, defense manufacturing, already filed in this register) but addresses a distinct target: the financial-sector infrastructure Ukraine assesses is used to circumvent existing sanctions on Russia's defense-industrial supply chain. The tranche designates 42 individuals and 35 legal entities — resident in Russia, Kyrgyzstan, and the United Arab Emirates — centred on the "A7" cryptocurrency-payment ecosystem, which the NSDC states is used to settle payments for components supplied for Russian missile production. Severity is set to 3 (quant-anchored on the disclosed 42-individual / 35-entity designee count), one step above the same-day Decree No. 102/2026 (severity 2, 27 entities): this tranche is larger in headcount and targets payment-rail infrastructure rather than a single manufacturing-supply chain, giving it broader potential disruptive reach across the sanctions-evasion network rather than a bounded set of suppliers.

The A7 ecosystem has been a recurring target across jurisdictions: the EU (July 2025) and Switzerland (August 2025) froze A7 LLC's funds over Moldova-election interference, and the US OFAC (August 2025) designated the successor Grinex exchange and the A7A5 stablecoin network for Russia-sanctions evasion. The UK's August 2025 action against a Kyrgyzstan/Luxembourg crypto-circumvention network is a close parallel to this decree's Kyrgyzstan-based designees. Decree No. 103/2026 extends that same-network pressure from Ukraine's own autonomous sanctions authority, reaching into the payment layer that finances missile component procurement rather than the component suppliers themselves.

Downstream implications

• Targets payment-rail infrastructure (A7 crypto network) rather than a

single supply chain, so disruption could propagate across multiple procurement channels that rely on the same settlement layer.

• Continues the near-weekly NSDC tranche cadence and the broader

multi-jurisdiction A7/A7A5 crackdown tracked in the western-russia-sanctions theme.

• Kyrgyzstan- and UAE-based designees extend Ukraine's reach into the

same third-country crypto/financial-services corridors the UK sanctioned in August 2025.

Open questions

• The full annex naming the 35 entities and 42 individuals was not

independently reproduced on the public pages consulted for this filing; the Rada legal-portal mirror and NSDC communique confirm the decree's existence, number, date, entry-into-force mechanism, and designee counts, but not the entity-level annex.

• Whether any of the Kyrgyzstan- or UAE-based designees overlap with

the UK's August 2025 Kyrgyzstan/Luxembourg network designations is unconfirmed.