EBA joins discussion on sanctions policy in the subsoil use sector

21/ 05/ 2025

On May 15, representatives of member companies of the European Business Association’s Subsoil Use Committee took part in a roundtable discussion titled “Sanctions Policy and Management of Seized Assets in the Subsoil Use Sector: Challenges, Conclusions, and the Future”, organised by the information agency NADRA.info. During the event, Dmytro Kashchuk, Head of the EBA Subsoil Use Committee, outlined the business community’s position on the current sanctions policy in the field of subsoil use. In particular, Dmytro stressed that the suspension of special permits for subsoil use leads to significant economic and environmental consequences for the state. Suspended permits effectively fall out of economic circulation: royalty payments cease, tax revenues decline. At the same time, the extraction of critically important energy resources and construction materials decreases, mineral reserves are lost due to natural geological processes, environmental risks increase, and jobs are cut. Moreover, the practice of suspending subsoil use permits due to sanctions imposed on the ultimate beneficial owner of the subsoil user is neither an effective mechanism nor fully aligned with the purpose of sanctions. Naturally, the business community understands and fully supports the idea that sanctions should prevent the use of subsoil resources to the detriment of national interests. However, businesses believe that this objective can be achieved without suspending the validity of special permits. The EBA is grateful to all event participants — in particular, the Ministry of Economy of Ukraine and ARMA — for supporting previously submitted proposals calling for the reform of sanctions policy in the subsoil use sector. The business community stands ready to continue the dialogue to develop effective solutions that will ensure both national security and sustainable economic development.

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During the event, Dmytro Kashchuk, Head of the EBA Subsoil Use Committee, outlined the business community’s position on the current sanctions policy in the field of subsoil use.

In particular, Dmytro stressed that the suspension of special permits for subsoil use leads to significant economic and environmental consequences for the state. Suspended permits effectively fall out of economic circulation: royalty payments cease, tax revenues decline. At the same time, the extraction of critically important energy resources and construction materials decreases, mineral reserves are lost due to natural geological processes, environmental risks increase, and jobs are cut.

Moreover, the practice of suspending subsoil use permits due to sanctions imposed on the ultimate beneficial owner of the subsoil user is neither an effective mechanism nor fully aligned with the purpose of sanctions.

Naturally, the business community understands and fully supports the idea that sanctions should prevent the use of subsoil resources to the detriment of national interests. However, businesses believe that this objective can be achieved without suspending the validity of special permits.

The EBA is grateful to all event participants — in particular, the Ministry of Economy of Ukraine and ARMA — for supporting previously submitted proposals calling for the reform of sanctions policy in the subsoil use sector. The business community stands ready to continue the dialogue to develop effective solutions that will ensure both national security and sustainable economic development.