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How to avoid
being sanctioned?

Individuals can be removed from the list, subject to close coordination with the Ukrainian authorities and sanctioning countries, when relevant proof of implementation of the actions outlined below is provided before the sanctions are imposed
Individual Sanctions Roadmap
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1. Oligarchs
1 publicly condemn or otherwise express disagreement with the Kremlin’s policy
2 suspend tax payments to the Russian government until the invasion ends, and
3 pledge a significant fraction of his/her personal fortune to a newly created Ukrainian Reconstruction Fund controlled by the Government of Ukraine as agreed by the Ukrainian state,
and/or
4 stop all business operations in Russia
5 Contact the National Agency for the Prevention of Corruption and provide evidence of the actions outlined above (only if the person has not yet been sanctioned)
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2. Senior government officials
1 Resignation
2 Contact the National Agency on Corruption Prevention and provide evidence of resignation (only if the person has not yet been sanctioned)
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3. Key executives and board members of Russian/Belarusian companies and banks, regardless of the citizenship of the individual
1 Resignation
2 Contact the National Agency on Corruption Prevention and provide evidence of resignation (only if the person has not yet been sanctioned)
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4. Key executives and board members of sanctioned companies and banks
1 Resignation
2 Contact the National Agency on Corruption Prevention and provide evidence of resignation (only if the person has not yet been sanctioned)
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5. Citizens of member countries of the sanctions coalition who hold management positions in Russian/Belarusian companies or banks
1 Resignation
2 Contact the National Agency on Corruption Prevention and provide evidence of resignation (only if the person has not yet been sanctioned)
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6. Propagandists
1 Resign from his/her position at the media outlet, educational establishment, public movement/association, or church
2 Publicly condemn or otherwise express disagreement with the Kremlin’s policy, and, if relevant
3 Contact the National Agency for the Prevention of Corruption and provide evidence of the actions outlined above (only if the person has not yet been sanctioned)
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7. Senior members of the governing bodies of Russian political parties who support Putin’s war against Ukraine
1 Publicly condemn or otherwise express disagreement with the Kremlin’s policy, and
2 Resign from his/her position at the respective political party
3 Contact the National Agency for the Prevention of Corruption and provide evidence of the actions outlined above (only if the person has not yet been sanctioned)
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8. Leadership and every elected representative of Putin’s «United Russia» political party
1 Publicly condemn or otherwise express disagreement with the Kremlin’s policy, and
2 Reject membership in «United Russia» party
3 Contact the National Agency for the Prevention of Corruption and provide evidence of the actions outlined above (only if the person has not yet been sanctioned)
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9. Family members of individuals listed in Categories (1) through (8)
1 Publicly condemn or otherwise express disagreement with the Kremlin’s policy, and
2 Disclose information about assets owned by persons subject to sanctions in accordance with the above categories (1) - (8)
3 Contact the National Agency for the Prevention of Corruption and provide evidence of the actions outlined above (only if the person has not yet been sanctioned)
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10. Persons who own assets of natural persons assigned to categories (1) - (9)
1 Publicly condemn or otherwise express disagreement with the Kremlin’s policy, and
2 Disclose information about assets owned by persons subject to sanctions in accordance with the above categories (1) - (9)
3 Contact the National Agency for the Prevention of Corruption and provide evidence of the actions outlined above (only if the person has not yet been sanctioned)