The European Court of Human Rights (ECHR) has recognized that M.S.L. does not have effective legal remedies for its complaints in Ukraine. This decision is the first substantive decision in the ECHR’s practice against Ukraine regarding the application of sanctions in accordance with the Ukrainian law “On Sanctions.”
As Elvira Lazarenko, a partner at the Barristers law firm, told the Interfax-Ukraine news agency, the relevant decision in the case of M.S.L., TOV v. UKRAINE” was published by the ECHR on October 16, 2025 (https://hudoc.echr.coe.int/#{%22itemid%22:[%22001-245275%22]}).
Lazarenko noted that “today, there is a fairly well-established practice of the Grand Chamber of the Supreme Court in ‘sanctions cases’, which states that there is limited possibility for judicial review of decisions by state bodies on the application of sanctions due to the discretionary powers of the National Security and Defense Council of Ukraine and the President of Ukraine to resolve issues of national security.”
“This practice has long been criticized by lawyers, as it demonstrated the de facto refusal of Ukrainian courts to review the factual grounds for the application of sanctions, i.e., a refusal to administer justice properly. The decision in M.S.L., TOV v. UKRAINE is important in that it raises questions about the limits of judicial review by Ukrainian courts of decisions on the application of sanctions and the possibility for courts to assess the significance of the risks that form the basis for the application of sanctions to individuals in accordance with the Ukrainian law “On Sanctions,” she said.
Lazarenko recalled that the case “M.S.L., TOV v. UKRAINE“ concerned the appeal by the company ”M.S.L.” against sanctions imposed on it by a decision of the National Security and Defense Council of Ukraine and enacted in 2015 by a decree of the President of Ukraine, with the subsequent extension of the sanctions by decrees in 2016 and 2017.
The applicant company complained that the imposition of sanctions, in particular the freezing of assets, constituted an interference with its rights guaranteed by Article 1 of Protocol No. 1 to the Convention, as it was prohibited from using and disposing of its assets. The applicant company also raised an issue under Article 13 of the Convention in connection with its lack of an effective remedy for the violation of its property rights.
At the national level, the Ukrainian courts dismissed the applicant company’s claim regarding the first Presidential Decree of Ukraine, and the company withdrew its claims regarding the second and third Decrees.
“In dismissing the company’s claim, the national courts refused to assess the factual grounds for the application of sanctions, referring to the discretionary powers of the authorities that had issued the contested decisions. The Grand Chamber of the Supreme Court indicated that the scope and results of the president’s assessment of the significance of the risks that served as the basis for imposing sanctions on the applicant company are beyond the scope of judicial review, since the administrative court does not have the competence to make decisions on matters of national security and defense,” the lawyer explained.
She noted that, in appealing to the ECHR, the company claimed, in particular, that the national courts had failed to administer justice because they had not examined whether the state authorities had sufficient grounds for imposing sanctions and whether those grounds were supported by any evidence.
“Moreover, the restriction of the scope of judicial review was not based on any provision of national law. In the company’s opinion, the president’s discretionary powers on national security issues should not limit judicial review by national courts or exempt courts from the obligation to verify the grounds for sanctions in accordance with the sanctions law,” Lazarenko said.
The lawyer noted that the ECHR, in turn, pointed out that the decisions of the national courts lacked a substantive judicial assessment of the decision to impose sanctions on the applicant company. In particular, the Supreme Court limited its analysis to the sole question of whether the decision of the NSDC and the first presidential decree complied with the formal requirements of the sanctions law and did not address the substance of the SBU’s allegations against the applicant company.
“Due to the fact that the courts did not verify whether the first presidential decree had a solid factual basis, the ECHR concluded that such judicial review could not be considered a sufficient procedural guarantee against arbitrariness. Accordingly, the ECHR recognized the interference with the applicant company’s right to peaceful enjoyment of property as unlawful,” she said.
In addition, Lazarenko noted that the ECHR, referring to its conclusion about the lack of adequate procedural safeguards against arbitrariness during the judicial review of the decision to apply sanctions, as well as the ineffectiveness of the company’s complaints to the SBU, concluded that the applicant company did not have effective legal remedies for its complaints.
“Given the established status of ECHR practice as a source of law, we expect an appropriate response to the ECHR’s decision in M.S.L., TOV v. UKRAINE,“ from the Administrative Court of Cassation and the Grand Chamber of the Supreme Court, as the courts of first and appellate instance designated to review decisions on the application of sanctions,” the lawyer concluded.
Ukrzaliznytsia (UZ), subject to European and state co-financing, plans to implement the Mostytska-Sknyliv project in the next two years and further develop the Lviv-Uzhhorod -Chop and Lviv-Chernivtsi-Vadul-Siret (Romania), which will allow Ukraine to begin restoring and realizing its unique geographical status, said Oleg Yakovenko, director of the strategy and transformation department at Ukrzaliznytsia.
“We also plan to obtain grant funds for the Mostyska-Sknyliv project, which will connect 80 km of European gauge track between the Polish border and Lviv. Next, we are currently conducting technical and economic studies on the corridors connecting Lviv, Chernivtsi, and Romania,” Yakovenko said during the Kyiv International Economic Forum (KIEF) on Thursday, October 16.
According to him, as part of Ukraine’s integration into the European Union, UZ plans to develop 1435 mm gauge railways and European transport corridors on the territory of Ukraine. The European integration reform of the railway industry also envisages a radical change in the functioning of the entire railway model in Ukraine.
“First of all, we are talking about market reform, which involves separating the infrastructure operator within Ukrzaliznytsia from the transport operators. This will allow us to liberalize the market in the future. It will also allow us to create market mechanisms specifically for transport,” Yakovenko explained.
He named the introduction of European rules on technical compatibility and interoperability as another element of the reform. This concerns technical safety standards, as well as changes to the safety management system.
The director of the strategy and transformation department at Ukrzaliznytsia noted that a draft law “On the safety and interoperability of Ukraine’s rail transport” is currently planned to be submitted for adoption by the end of the year, while next year the company expects a law on market liberalization to be introduced.
As Yakovenko explained, it is expected that a so-called infrastructure access tariff will be formed, according to which market participants will be able to purchase certain access to transport routes from the infrastructure operator on a competitive basis.
“These tariffs will be regulated, i.e., they will be formed in accordance with the tariff formation procedure and will reflect economically justified tariffs in accordance with European rules,” emphasized the representative of Ukrzaliznytsia.
It is noted that the new system will introduce separate PSO (Public Service Obligation) contracts between passenger carriers and the state at the national level, as well as between carriers and local authorities. This should remove the financial burden from freight transport.
As reported, in September, a section of standard (“European”) 1435 mm gauge railway was opened between Uzhhorod and Chop in Zakarpattia Oblast, which will allow for direct rail connections between Uzhhorod and a number of European capitals.
In addition, in January 2025, it was reported that the reconstruction of the railway track on the section “Polish State Border – Mostyska II – Sknyliv (Lviv)” would be postponed until 2026, although in February 2024, the then Deputy Prime Minister for Recovery – Minister of Community, Territory and Infrastructure Development Oleksandr Kubrakov announced the start of construction by the end of 2024. Later it became known that Ukraine had failed to attract Connecting Europe Facility (CEF) funding for the project. It was reported that the US Agency for International Development (USAID) was considering financing 50% of the project’s cost, but it has since been liquidated.
CONSTRUCTION, EU, European gauge, GRANT, LVIV, UKRZALIZNYTSIA
Initial registrations of new and used buses (including minibuses) in Ukraine in September 2025 decreased by 6% compared to the same month last year, to 233 units, UkrAvtoprom reported on its Telegram channel.
Compared to August of this year, when 259 buses were registered, the market shrank by 10%.
The share of new vehicles in September’s volume was 58%, while last year it was 63%.
Domestic ZAZ buses took the lead among new buses with 38 vehicles registered, while in September 2024, these buses ranked third with 24 vehicles.
Second place went to new Ataman buses from the Cherkasy Bus factory, with 29 units, which also ranked second last year with sales of 37 vehicles.
Etalon buses came in third among new buses with 19 units, having been the leaders a year ago with 60 buses.
Among used buses, Mercedes-Benz was the most frequently registered in September with 49 units, followed by VDL and Van Hool with 8 units each.
According to UkrAvtoprom, a total of 1,888 buses were added to Ukraine’s bus fleet in January-September 2025 (+33% compared to the same period in 2024). Of these, 935 were new (+16%) and 953 were used (+56%).
As reported, in 2024, initial registrations of new and used buses decreased by 19% compared to 2023, to 2,241 units, including new buses by 24%, to 1,296 units, and used buses by 12%, to 945 units.
According to Serbian Economist, Alcazar Energy, an international company operating in Serbia, among other countries, intends to increase its investment in Montenegro from the previously planned $200 million to $500 million, co-founder and managing partner Daniel Calderon said in an interview with the media.
According to Calderon, the company will begin construction of the 118.8 MW Bijela wind farm in the first quarter of 2026. The investment in the project will amount to about $200 million.
“We are preparing the site and purchasing equipment — this is a large and strategically important project. But this is only the first part of our investments in Montenegro,” Calderon said.
He added that over the next five years, the company’s investments could grow to half a billion dollars, and the total investment in the development of renewable energy sources in Montenegro could reach $4-5 billion by 2040.
“We expect that about 10% of these investments will go to Alcazar Energy projects, and these will be the first steps in a major energy transformation of the region,” Calderon said.
According to him, the company is considering the possibility of implementing several additional projects in Montenegro, but the details are not yet disclosed.
At the EU-Montenegro conference, 14 joint projects with European companies were presented, half of which are related to investments in wind farms, solar parks, and energy storage systems.
Alcazar Energy is an international company specializing in the development, construction, and management of renewable energy facilities.
Founded in 2014, it is headquartered in Dubai (UAE). The company is active in the MENAT region (Middle East, North Africa, Turkey) and the Balkans.
Its key projects include wind farms and solar power plants in Serbia, Jordan, Egypt, and Turkey. Alcazar recently began construction of the largest wind farm in the Western Balkans in North Macedonia.
Source: https://t.me/relocationrs/1587
Prices for construction and installation work in Ukraine in August 2025 rose by 5.4% compared to August 2024, according to the State Statistics Service (SSS).
According to the statistics agency, in August 2025 compared to August 2024, prices increased in all segments of construction: in residential construction, the increase was 5.7%, in non-residential construction – 5.5%, and in engineering construction – 5.2%. At the same time, compared to July of this year, prices rose by 0.2%, 0.1%, and 0.6%, respectively.
In August 2025 to December 2024, prices for construction and installation works increased by 4%, while in the first eight months of 2025, construction prices increased by 6% compared to the same period a year earlier.
As reported, in 2024, prices for construction and installation works increased by 7.9% compared to the previous year, and in 2023, they rose by 15.8% compared to 2022.
The State Statistics Service indicated that the figures do not include temporarily occupied territories and parts of territories where hostilities are (were) ongoing.
The OKKO Group, which includes the operator of the Galnaftogaz concern’s network of gas stations, plans to commission its first 147 MW wind farm in Ivanychi, Volyn Oblast, by the end of 2025 or the first quarter of 2026, said Vasyl Danylak, CEO of OKKO GROUP holding and co-founder of GORO Mountain Resort.
“I hope that by the end of this year, or possibly in the first quarter of next year, we will commission a 147 MW wind farm, which we are building jointly with the EBRD, IFC, and CDB,” Danylak said during the Kyiv International Economic Forum in Kyiv on Thursday.
According to him, the Group has already “launched” a new wind energy project next to the first one – the 192 MW Zatyrintsy wind farm.
In addition, Danylak noted that OKKO has completed the first phase of its bioethanol plant and is building the GORO Mountain Resort hotel complex at a “good pace.”
“We have built the silo section and completed construction work on the large bioethanol plant itself, and we plan to commission it next year. Our hotel has been under construction for a year now, and progress is very good. I hope that in the coming years we will make a big mark on the tourist map not only of Ukraine but also of Europe,” the head of OKKO shared his plans.
He noted that the Group is motivated to make large investments by new opportunities that have recently opened up.
“On the one hand, the war is a great tragedy that has exposed a number of problems in various sectors, particularly in energy. It turned out that the huge Soviet energy facilities were vulnerable. Therefore, the government and the Ministry of Energy set a course for decentralization of power generation. This is absolutely right. At that time, we had a shrinking fuel market and decided to work in related industries,” explained Danylyak.
He cited the transparency of the company’s activities, the clear fulfillment of its obligations, and a professional, motivated team as the keys to OKKO’s success and active cooperation with international financial organizations.
As reported, over the next five years, OKKO plans to have approximately 600 MW of capacity in wind energy, 200 MW in solar energy, and 150 MW in energy storage facilities (ESF).
In particular, the OKKO Group is building the 147 MW Ivanychi WPP in the Volyn region with a total cost of EUR 225 million (excluding VAT) and is seeking financing for its second wind energy project in this region – the 192 MW Zatyrintsy WPP, which is estimated at EUR 250 million (excluding VAT).
The Group also won a five-year special auction held by NPC Ukrenergo for the provision of power system balancing services, in which it announced the installation of a 20 MW energy storage facility (ESF). The commissioning of the ESF was announced in April.
In addition, the group plans to open a new 60,000-tonne elevator by autumn 2025 and a bioethanol plant in summer 2026. An important component of OKKO’s agricultural portfolio is its partnership with the Gadz-Agro enterprise in the Ternopil region, in which the company acquired a stake in 2023. The company cultivates 26,000 hectares of land and has about 10,000 head of cattle, of which 5,000 are dairy cows. It is also one of the largest horticultural farms in Ukraine, but OKKO has decided not to integrate the horticultural part of the business.
OKKO Group unites more than 10 diverse businesses in the fields of manufacturing, trade, construction, insurance, services, and other services. The flagship company of the group is Halnaftogaz, which operates one of the largest petrol station chains in Ukraine under the OKKO brand, with almost 400 petrol stations.
The founder and ultimate beneficiary of the group is Vitaliy Antonov.
