Zelenskyy Enacts Personal Sanctions Against Two Figures in Operation “Midas.” What Does This Mean?

The website of the Office of the President published a Decree putting into effect the NSDC sanctions imposed on two key figures of NABU’s recent high-profile investigation — Tymur Mindich and Oleksandr Tsukerman.

In practice, the NSDC applied more than half of all available sanctions, including measures such as 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.

However, the measures with the most tangible impact on these individuals are likely to be financial sanctions. For example, the freezing of Tymur Mindich’s assets should also extend to his 50% ownership stake in Kvartal-95 LLC.

That said, it is important to understand that the law does not require government bodies to block assets immediately. Oversight of the asset-freezing process falls to the Ministry of Justice, which until recently was headed by Herman Halushchenko — another figure mentioned in the “Mindich tapes.” It is also worth noting that circumvention of sanctions is still not criminalized in Ukraine.

It is equally important to emphasize that the imposition of sanctions is not a response to the alleged offenses exposed by the NABU and the SAPO. Sanctions are not a form of legal liability. In this context, it is vital for the authorities to demonstrate commitment to the anti-corruption agenda — not only refraining from obstructing the investigation but actively supporting it.

As reported earlier, Mindich and Tsukerman were notified of suspicion by the NABU and the SAPO but left Ukraine shortly before searches began on November 10, 2025.