The Ukrainian registries, EU instruments and due-diligence terms that recur in this work, defined plainly. Where a term is routinely misunderstood, the definition says what it does not mean as well as what it does.
The eight-digit identifier assigned to every legal entity registered in Ukraine, issued under the Unified State Register of Enterprises and Organisations of Ukraine. It is the Ukrainian equivalent of a company registration number and the only reliable way to identify a Ukrainian company, because names are frequently duplicated, transliterated inconsistently and changed.
The Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations — Ukraine's principal company registry. It records legal status, registered address, directors, share capital and declared ultimate beneficial owners. Registration in the EDR establishes legal existence; it says nothing about a company's capacity to perform.
Ukraine's public electronic procurement system, through which state and municipal tenders are published and awarded. Its open data covers who bid, who won, at what value and how often, making it one of the most useful sources on Ukrainian company behaviour. It operates under Ukrainian procurement law as amended under martial law.
Ukraine's National Agency on Corruption Prevention, which maintains the register of public officials' asset declarations and the national register of persons subject to Ukrainian sanctions. Ukrainian designations recorded here do not necessarily appear on EU, US or UK lists, so screening against those lists alone can miss them.
Ukraine's public register of court decisions, which publishes judgments across the court system. It allows a company's litigation history to be reconstructed, including commercial disputes, insolvency proceedings and enforcement actions. It is a Ukrainian-language source, and machine translation regularly mistakes which party is which.
The legal regime in force in Ukraine since February 2022, which alters procurement thresholds and procedures, affects court operation and the enforceability of judgments, underpins conscription and movement restrictions, and provides the basis for NBU capital controls. It changes what a Ukrainian counterparty can lawfully and practically do.
Restrictions imposed by the National Bank of Ukraine on cross-border payments, currency conversion and capital movement under martial law. In practice they affect settlement timelines, the repatriation of funds and hryvnia convertibility, and they are a recurring constraint on whether a Ukrainian contract can be performed as written.
The natural person who ultimately owns or controls a legal entity, whether through direct shareholding, an ownership chain, or control exercised by other means such as board appointment rights or veto rights. Identifying the UBO, rather than the immediate shareholder, is what sanctions ownership-and-control analysis requires.
The process of determining that two or more records refer to the same real-world company or person. In Ukrainian work this means reconciling Cyrillic names, competing Latin transliterations, legacy romanisations, abbreviated legal forms and duplicated company names, anchored on the EDRPOU identifier wherever one exists.
An individual entrusted with a prominent public function, together with their close associates and family members. PEP status is not an allegation of wrongdoing; it is a trigger for enhanced scrutiny. PEP data drawn from open sources is supplementary and is not authoritative for regulated know-your-customer determinations.
The practice of carrying, with every material fact, the source it came from and the date it was true. Provenance is what allows a finding to be re-checked, allows staleness to be detected, and allows what is established to be distinguished from what is inferred. Without it, an evidence base cannot be audited.
Searching news and media sources for reported allegations of wrongdoing connected to a counterparty. It surfaces what has been reported, not what has been established, and it is prone to both false positives from name collisions and false negatives where reporting is absent, suppressed or in a language the search does not cover.
The Global Database of Events, Language and Tone, an open dataset that monitors news media worldwide and codes reported events using the CAMEO taxonomy. It supports adverse media search and conflict-event intensity measurement. Because it indexes media reporting, presence in GDELT reflects what was reported rather than what occurred.
The EU test for whether an unlisted entity is caught by sanctions applying to a designated person. An entity is caught where a designated person holds more than 50% of the proprietary rights or a majority interest, and separately where a designated person exercises control regardless of shareholding — for example through board appointment rights, veto rights, or the ability to direct the entity in practice.
Structuring a transaction, ownership chain or supply route so that goods, funds or services reach a sanctioned party without a direct, screenable relationship. Because circumvention is designed not to appear on a list, it is not detectable by name screening and requires analysis of ownership chains, trade routes and counterparty behaviour.
Items that have a civilian use but can also be applied to military or security ends, controlled in the European Union under Regulation (EU) 2021/821. The category is wider than it sounds: semiconductors, software with cryptographic functions, industrial machinery, components applicable to unmanned aerial vehicles, telecommunications equipment and surveillance technology all fall within it.
The intellectual-property use reporting obligation introduced by the twentieth package of EU Russia-related restrictive measures, adopted on 23 April 2026. It requires reporting on the use of intellectual property in specified circumstances, extending sanctions compliance beyond the movement of goods and funds into the licensing and use of rights.
The Financial Action Task Force's two public listings. The grey list covers jurisdictions under increased monitoring that have committed to an action plan; the black list covers jurisdictions subject to a call for action. FATF updates both three times per year, so a listing check has a short shelf life.
Exclusion of a firm or individual from eligibility for contracts funded by a particular institution, typically following a finding of fraud, corruption, collusion or coercion. Development banks including the World Bank, EBRD, EIB, ADB, IDB and AfDB each publish their own debarment lists, and several recognise each other's decisions through cross-debarment arrangements.
The EU Corporate Sustainability Due Diligence Directive, which requires in-scope companies to identify, prevent, mitigate and bring to an end adverse human rights and environmental impacts across their chains of activity. It applies to EU companies with more than 5,000 employees and EUR 1.5 billion worldwide turnover, and to non-EU companies with EUR 1.5 billion of EU turnover.
The process of identifying, preventing, mitigating and accounting for adverse human rights impacts connected to a company's operations and business relationships. In conflict-affected markets, standard questionnaire-based HRDD is generally inadequate, because self-reported answers cannot be corroborated at distance and the material risks do not appear on a standard form.
The elevated standard expected where operations touch a conflict-affected or high-risk area, reflecting that ordinary commercial due diligence does not surface conflict-specific risks. It extends to frontline proximity, occupied and contested territory, mine contamination, grid and infrastructure dependence, conscription-driven labour shortages and war-risk insurance terms.
The list of goods produced by child or forced labour maintained by the United States Department of Labor under the Trafficking Victims Protection Reauthorization Act. It is published by country and commodity, making it a country- and product-level screening signal rather than a finding about any specific supplier.
The United States Uyghur Forced Labor Prevention Act, which creates a rebuttable presumption that goods made wholly or partly in Xinjiang, or by entities on its associated list, are made with forced labour and are barred from entry into the United States. Rebutting the presumption requires supply-chain tracing to the raw-material level.
The European Union's dedicated financing instrument for Ukraine's recovery, reconstruction and modernisation, providing EUR 50 billion through 2027. Projects financed under it are procured through Prozorro and through development finance institution portals, and carry EU procurement framework requirements at project level in addition to a contractor's own corporate compliance obligations.
The joint assessment of Ukraine's war damage and recovery needs produced by the World Bank with the Government of Ukraine, the European Commission and the United Nations. Successive editions place recovery costs above $480 billion, and the assessment is the reference point most reconstruction financing is sized against.
The environmental and social requirements applied by the International Finance Corporation to the projects it finances, covering risk management, labour conditions, resource efficiency, community health and safety, land acquisition, biodiversity, indigenous peoples and cultural heritage. They are widely adopted as a benchmark by other lenders through the Equator Principles.
The European Bank for Reconstruction and Development's framework of environmental and social requirements for the projects it finances, alongside its own Procurement Policies and Rules. Contractors on EBRD-backed projects are bound by both, which do not always align with Ukrainian domestic procurement requirements or with other development banks' frameworks.
Definitions settle vocabulary, not decisions. If you have a counterparty, a site or a transaction where these terms have to be applied to real facts, write to us.