How to ensure the effectiveness of sanctions against the aggressor state without paralyzing your own economy?

One of the key topics was the situation around Smart-Holding's gas production enterprises in Poltava and Kharkiv regions, which were forced to stop operations due to sanctions legislation. 

For almost 1.5 years (April 2023 – June 2024), special permits for the use of subsoil owned by the companies of the Smart Energy group were suspended due to the Decision of the National Security and Defense Council of Ukraine on the imposition of sanctions on the former beneficiary. During this time, the state lost 195 million cubic meters. m of gas and UAH 1.65 billion in tax revenues. Later, state authorities, realizing the importance of the gas industry for the country, decided to unblock the work of companies and a corrective decision was made by the National Security and Defense Council. Thanks to the titanic professional work of the Smart Energy Group team, it was possible to resume the operation of wells within a month, which made it possible to continue hydrocarbon production. But in October 2024, the state again imposed sanctions without assessing the consequences of losses for the subsoil and the economy, this time against the current beneficial owners – trustees, citizens of Cyprus, as a result of which the group's companies were again forced to stop their activities at the beginning of 2025. 

 "Sanctions should hit the enemy, not Ukraine," Ivan Gerasimovych, CEO of Smart-Holding, voiced a clear position. Thus, due to short-sighted government decisions, against the background of the proven fact of insufficiency of natural gas in storage facilities and the need to import it at high European prices, by the end of 2025, the energy system will lose 85.5 million cubic meters of gas, which will not be able to be produced by Smart Energy group companies, and the budget will lose UAH 1.2 billion in taxes.

The participants of the round table agreed that the sanctions policy should remain an effective tool for putting pressure on the aggressor state, but at the same time not pose a threat to the economic stability of Ukraine itself.

"We support sanctions as a tool for influencing the aggressor state. At the same time, it is important that this instrument does not harm the Ukrainian economy and does not create a critical dependence on imported resources. Companies that have operated in the legal field, paid taxes regularly and provided jobs should be able to continue working. We are ready for dialogue, we are ready to work for the benefit of Ukraine. I have repeatedly appealed to the Minister of Economy, Yulia Svyrydenko, in order to involve businesses in the meetings of the interagency working group on sanctions policy in order to hear arguments and find solutions, to unblock enterprises that produce gas for Ukraine. And I am sincerely grateful to the Ministry of Economy today for understanding and supporting the position that Ukrainian business should work and produce such scarce gas," Gerasimovich said. 

"We need subsoil that is used. The state grants special permits for the use of subsoil, because the state benefits from the use of subsoil on behalf of the Ukrainian people - this is a direct norm of the Constitution of Ukraine," Volodymyr Boyko, editor-in-chief of NADRA.info, summed up.

 At the beginning of 2025, Smart Energy Group, due to the suspension of three special permits, stopped gas production of two gas producing enterprises — the Representative Office of Regal Petroleum Corporation Limited in the Poltava region and Prom-Energo Product LLC in the frontline Kharkiv region, which are 100% owned by the British company Enwell Energy. The Smart Energy Group of Companies is part of the Smart Holding investment group, implements projects for the exploration and industrial development of hydrocarbon deposits and was one of the five largest private gas producers in Ukraine, producing a total of more than 1 million cubic meters at the beginning of the full-scale Russian military aggression. m of gas per day.