Schrödinger’s Sanctions: What the SSU Did Not See in the Ivaniushchenko Case

The SSS did not find sufficient grounds to apply sanctions against former Party of Regions MP Yurii Ivaniushchenko. The NABU is searching for him in a case concerning the alleged laundering of state-owned land near Kyiv worth more than UAH 160 million.

The NABU petitioned the Security Service of Ukraine to apply sanctions against Ivaniushchenko in March 2026. In its response, the SSU stated that the materials received from the Bureau did not contain sufficient information that Ivaniushchenko had inflicted harm on Ukraine’s national security, sovereignty, or territorial integrity. At the same time, the Service noted that it was prepared to review the materials again once they had been supplemented.

This is despite the fact that both the suspicion notice and the HACC ruling contain direct references to the fact that, as far back as 2001, this long-time crony of Yanukovych was expelled from Monaco on suspicion of ties to representatives of Russian organized crime groups. The same documents also note that, beginning in 2014, Ivaniushchenko was on the European Union’s sanctions lists and was the subject of criminal cases in Ukraine, Monaco, and Switzerland.

In addition, investigative journalists also found that in 2025 the SSU itself had referred to Ivaniushchenko as an FSB resident in the “DPR” while investigating the case of Russian agents inside the NABU.

This raises an obvious question: why did the SSU not see sufficient grounds for sanctions in the materials of NABU’s criminal case, when one of the suspects is a person with documented ties to Russian organized crime groups and to schemes for taking over assets in the temporarily occupied territories? And why, at the same time, did the SSU use that very same person in its public communications to substantiate cases against NABU’s own employees?

How do sanctions work?

Yurii Ivaniushchenko, also known as “Yura from Yenakiieve,” is a former Party of Regions MP of the 6th and 7th convocations and one of Viktor Yanukovych’s closest associates. After the Revolution of Dignity, he fled the country and has since lived primarily in Monaco. But despite all the cases opened against him, Ivaniushchenko is still not under sanctions.

A reminder here: sanctions in Ukraine are governed by the dedicated Law on Sanctions. Under this law, proposals to apply such restrictions to a specific individual, company, or state can be submitted to the NSDC by parliament, the president, the Cabinet of Ministers, the National Bank, or the Security Service. And although the SSU is not the only body that can propose sanctions against someone, it is entirely logical that the NABU turned to it as a law enforcement agency.

The grounds for applying sanctions, while described fairly broadly in the law, form an exhaustive list, and all of them relate to protecting the state’s national interests or the rights of its citizens. That said, we cannot know for certain why sanctions are imposed on any specific person, since such reasoning is not made public.

By way of example, we can recall the rapid imposition of NSDC sanctions on Timur Mindich and Oleksandr Tsukerman following NABU’s release of materials from the Midas case.

At the time, the tapes published by NABU referred, among other things, to “two [million] to Moscow.” And although we cannot assert that this was precisely what underpinned the sanctions, it is clear that, unlike in the Ivaniushchenko case, there was enough evidence of activity threatening national security to impose on Mindich and Tsukerman more than half of all available restrictions. The package even included deprivation of state awards — which Mindich and Tsukerman do not hold — and a ban on foreign non-military vessels and warships entering Ukraine’s territorial waters, although that sanction also has little bearing on these particular figures in NABU’s case.

At the same time, we do not know the reasoning behind the sanctions imposed on Mindich, Tsukerman, or other figures on such sanctions lists. The general problem with Ukrainian sanctions is that we cannot find out which specific actions and supporting evidence underpin the application of such measures to any given person. This is because sanctions are often based on the materials of criminal cases in which the sanctioned individuals are involved, and that information cannot be disclosed. That said, under the EU standard, the NSDC’s decision should at least include a general statement of reasons for sanctioning a person.

In Ivaniushchenko’s case, once again, we can rely on the materials the NABU has published, the contents of court rulings, and the SSU’s own public statement — all of which refer to his ties to Russia. Despite this, it is impossible to understand why the NSDC applied sanctions against Mindich and Tsukerman but the SSU refused to take the same approach with Ivaniushchenko, because the law does not require the reasoning behind such decisions to be made public.

How does Ivaniushchenko’s citizenship affect the application of sanctions?

There is one more contested aspect to the “Yura from Yenakiieve” case — his Ukrainian citizenship. The practice of states imposing sanctions on their own citizens is generally very rare, since it runs counter to the very logic of such measures. For its own citizens, the state has internal means of influence — chief among them criminal liability for offenses against national security and the like.

Under the law, all sanctions other than deprivation of state awards may be applied to Ukrainian citizens only if those individuals engage in terrorist activity. But there is room for maneuver when it comes to people who hold dual citizenship, have been stripped of Ukrainian citizenship, or hold only a residence permit. In particular, the Law on Citizenship of Ukraine sets out, as a ground for termination of citizenship, the voluntary acquisition by a person of citizenship of a state recognized by the Verkhovna Rada of Ukraine as an aggressor state or occupying state.

The European Convention on Nationality likewise allows a state to deprive a person of citizenship if they have voluntarily acquired the citizenship of another country or if their conduct seriously harms the state’s interests.

Many sanctioned Ukrainian citizens have also held Russian citizenship — Viktor Yanukovych, for example. As for other cases, Ihor Kolomoiskyi was stripped of Ukrainian citizenship by a presidential decree, and Hennadii Boholiubov holds only a permanent residence permit in Ukraine (although the sanctions register lists him as a Ukrainian citizen). 

In the cases of Petro Poroshenko, Kostiantyn Zhevaho, and, more recently, Andrii Bohdan, however, the NSDC must have evidence of their terrorist activity, since these individuals do not hold any citizenship other than Ukrainian and have not been stripped of it.

As for Yurii Ivaniushchenko, according to Radio Liberty, back in 2004 he obtained a passport of a citizen of the Russian Federation in Rostov-on-Don. In the same investigation, journalists indicate that the former MP held at least two Russian international passports and used them to travel to Russia. In particular, since the start of the full-scale invasion, he has flown there at least ten times. 

Thus, Ivaniushchenko’s citizenship should not stand in the way of applying NSDC sanctions against him — given the now-established practice of sanctioning even Ukrainian citizens who hold no other passport.

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The Ivaniushchenko story is yet another piece of evidence that Ukraine’s sanctions policy has shifted from confronting Russia to using such measures as a substitute for justice or a tool of selective political pressure.

A situation in which the SSU itself publicly labels someone an “FSB resident in the ‘DPR’” and then does not find sufficient grounds to impose sanctions on that person amounts, at the very least, to institutional inconsistency that requires a better explanation than the one NABU received in response to its petition.

As long as the reasoning behind sanctions remains opaque and their application remains situational and reactive, this instrument will continue to be perceived not as part of the national security system, but as a lever whose use depends on the political climate.