DECODING: Zelensky sanctions 67 collaborators and structures in occupied territories

DECODING: Zelensky sanctions 67 collaborators and structures in occupied territories

Introduction: two decrees, 67 names, a legal war without a truce

Decrees signed in silence, consequences that resonate

On June 26, 2026, President Volodymyr Zelensky signed decrees 501/2026 and 502/2026, imposing sanctions against 67 collaborators and organizations operating in the temporarily occupied territories of Ukraine. The news passed almost unnoticed in the stream of military communiqués, strike reports, and diplomatic statements. Yet it says something essential about the war Ukraine is waging on its own soil: a war not only of trenches and drones, but of registries, identities, and accountability.

These 67 individuals and entities do not hold rifles. They manage kindergartens, hospitals, foundries, meteorological companies. They made the choice — active, documented — to collaborate with the Russian occupier. And now their names appear in an official Ukrainian document, transmitted to international partners. This is not a symbolic blacklist. It is the first chapter of an accountability process that may take years, but that begins now.

The logic behind targeting civilian collaborators

To understand the reach of these decrees, one must step outside the military framework. When Russia occupies Ukrainian territory, it cannot function without a local human infrastructure: teachers, doctors, administrators, engineers who agree to keep working under the occupier's flag. These people allow the occupation to normalize, to acquire the appearance of governance, to present itself to the world as a fait accompli.

Kyiv's sanctions aim to break that normalization. By naming collaborators, freezing their potential assets, and flagging them to international partners, Ukraine sends a message to those still hesitating: collaboration carries a documented price. That message is aimed as much at residents of occupied zones as at allied governments. And for the United States, the European Union, and their legal partners, these lists constitute raw material for future extradition proceedings, asset seizures, or prosecutions.

Raisa Prylipko: a kindergarten director turned instrument of deportation

A civilian title, a criminal function

Raisa Prylipko is one of the most thoroughly documented cases among the 67 sanctioned individuals. Director of a kindergarten in the occupied territories of the Donetsk region, she allegedly took an active role in organizing the transfer of Ukrainian children to Russia. This is not an abstract accusation: documents, testimonies, and public data on the deportation of Ukrainian children — estimated at several tens of thousands since 2022 — make it possible to trace responsibility back to the occupation's educational institutions.

The Prylipko case illustrates the deep mechanics of the Russian collaborationist system in Ukraine. The occupier does not deport children with armored vehicles. It uses apparently functional educational structures, staffed by local collaborators, to produce administrative acts that look legal. The director signs the paper. The child gets on a bus. The deed is done. This mechanism has been documented by Human Rights Watch, the ICC Office of the Prosecutor, and the Ukrainian-international joint investigation team — and it is this mechanism that Zelensky's decrees are beginning to dismantle, one name at a time.

The symbolic and legal reach of targeting educators

Placing a kindergarten director on a sanctions list is a deliberate political act. It signals that Ukraine refuses to distinguish between "passive complicity" and "active collaboration" when it comes to the deportation of children. Under international humanitarian law, the transfer of children from an occupied territory to the occupying country constitutes a grave violation of the Geneva Conventions and the Convention on the Rights of the Child. The ICC has indeed issued arrest warrants against Vladimir Putin and Russian Children's Rights Commissioner Maria Lvova-Belova precisely for these acts.

By sanctioning the local executors of this policy, Kyiv is weaving the web that will connect, before an international jurisdiction, the orders from the top to the acts in the field. Criminal liability does not stop with generals and ministers. It reaches down to those who signed the transfer forms in the occupied kindergartens of Donetsk.

Mykola Andros: Melitopol's hospital at the service of Russian troops

A medical director caught in the gears of occupation

Mykola Andros, director of a hospital in Melitopol in the occupied Zaporizhzhia region, is among the 67 sanctioned individuals for reorganizing his hospital's services to prioritize the treatment of wounded Russian soldiers and to support the logistical needs of the occupation army. Melitopol, a city of roughly 150,000 inhabitants before the invasion, has been under Russian occupation since March 1, 2022. Since then, its medical infrastructure has been progressively integrated into the support system for Russian armed forces.

The Andros case raises a question that war forces one to ask: how far does a doctor's or hospital director's obligation extend under military occupation? International humanitarian law stipulates that health professionals cannot be compelled to treat only the soldiers of an occupying power to the detriment of the local civilian population. When a hospital director makes that choice deliberately, and not under documented duress, he steps out of the zone of medical neutrality and into that of collaboration.

Melitopol: laboratory of prolonged occupation

Melitopol has since 2022 been one of the emblematic cities of prolonged occupation, with its reorganized institutions, Russian-language schools, pro-Russian city hall, and enterprises under the occupier's control. The legitimate mayor, Ivan Fedorov, was kidnapped by the Russians in the first days of the occupation before being released. Since then, the city has functioned as a laboratory of occupation mechanics: how to transform a Ukrainian administration into a de facto Russian one, with the complicity of local collaborators.

The sanctions against Andros and other actors in Melitopol send a direct signal to collaborators in all occupied cities: Ukraine's institutional memory is long, and the eventual liberation of these territories will be accompanied by an accountability process. That is not an abstract promise. It is a documented policy, decree by decree, from Kyiv.

The sanctioned companies: drones, weather, and metallurgy in service of the Russian military complex

Civilian companies integrated into the Russian chain of command

Beyond individuals, decrees 501/2026 and 502/2026 target organizations whose activities directly support Russia's military-industrial complex in occupied territories. Among them are companies involved in the manufacture of components for Russian military drones — a supply chain that has become central to Russia's strategy of striking Ukrainian infrastructure. These drones, often Iranian Shaheds assembled or modified in Russia, are now partially produced in industrial entities of the occupied territories.

A particularly notable case involves companies supplying meteorological services to Russian military aviation. These companies, ostensibly civilian, play a concrete operational role: they provide the meteorological data needed for planning air strikes and long-range drone missions. Sanctioning these entities means acknowledging that modern warfare erases the boundary between civilian and military in the occupier's economy.

Soyuzmetalservice and the metallurgical supply chain

The company Soyuzmetalservice, a metallurgical firm identified in the decrees, illustrates another dimension of support for Russia's war effort: the supply of raw materials and metal components for weapons production. In occupied territories — particularly in the Donetsk and Luhansk regions where Soviet heavy industry has existed for decades — metallurgical plants have been progressively converted or integrated into the supply chain of the Russian military-industrial complex.

The targeting of these economic entities signals that Kyiv no longer distinguishes between sanctioning individuals and sanctioning industrial ecosystems. The objective is to map the entire economic network that allows the occupation to finance itself and the Russian army to resupply — and to transmit that map to partners tasked with designing the next multilateral sanctions packages.

The Ukrainian sanctions mechanism: scope and limits

What sanctions can do — and what they cannot

Ukrainian sanctions work differently from Western sanctions. They do not freeze assets in banks in New York or Zurich — the individuals sanctioned by Kyiv generally have no assets in territory controlled by Ukraine. Their immediate value is therefore primarily symbolic and documentary: they create an official registry, signed by the president, establishing individual or institutional responsibility for collaboration with the occupier.

But their reach extends beyond the symbolic on one crucial point: Kyiv has announced transmitting this information to its international partners. This means the United States, the United Kingdom, the European Union, and other partners can — and are encouraged to — adopt parallel measures targeting the same individuals or entities. A collaborator from Melitopol whose assets are frozen by Kyiv may also find themselves targeted by OFAC, European sanctions regulations, or UK orders — should those bodies decide to act on Ukrainian evidence.

Articulation with international criminal proceedings

The most enduring value of these decrees may lie in their articulation with ongoing criminal proceedings. The ICC Office of the Prosecutor, the joint investigation team supervised by Eurojust, the Special Tribunal for the Crime of Aggression in its constitutive phase — all these bodies are seeking evidence of individual responsibility, a causal chain connecting the orders from Moscow to the acts in the field.

Decrees 501/2026 and 502/2026 feed that chain. They establish that the Ukrainian state has officially identified, documented, and sanctioned individuals for specific acts — child deportation, requisitioning hospitals for the occupation army, manufacturing military components. These documents can become evidentiary exhibits. This is not rhetoric: it is procedure.

The context of the decrees: Ukraine builds its post-occupation doctrine

A systematic accountability policy since 2022

The decrees of June 26, 2026 are not isolated events. Since 2022, Ukraine has developed a systematic policy of documenting and holding accountable those who collaborate with the occupier. The Ukrainian Prosecutor General's Office has opened tens of thousands of criminal investigations for collaboration, treason, and war crimes. The collaborators' registry is regularly updated. The presidential sanctions lists constitute the public and diplomatic component of this policy.

This approach is part of a broader doctrine: that of a post-occupation Ukraine that cannot simply liberate its territories and wipe the slate clean. The reintegration of occupied zones will require distinguishing between those who actively collaborated and those who resisted or simply survived — a distinction that only rigorous documentation during the occupation can establish. Zelensky's decrees are therefore as much oriented toward the future as toward the past.

Lessons from history: denazification, lustration, and transitional justice

History offers useful precedents, not all of them encouraging. After World War Two, the denazification processes in liberated zones of Europe showed the limits of mass accountability: too slow, too political, often incomplete. In central and eastern Europe, the lustration processes of the 1990s revealed the tensions between transitional justice and social reconciliation.

Ukraine is aware of these precedents. Its policy of individual sanctions — targeted, documented, transmitted to partners — seeks to avoid both total impunity and indiscriminate repression. That is not an easy equation to solve. But decrees 501/2026 and 502/2026 indicate that Kyiv has chosen precision over vengeance.

The 67 sanctioned in regional context: Donetsk, Zaporizhzhia, Kherson, Luhansk

A geography of collaboration

The geographical distribution of the 67 sanctioned individuals mirrors the map of Russian occupation. The regions of Donetsk, Zaporizhzhia, Kherson, and Luhansk concentrate the bulk of the collaborators identified in both decrees. These four regions — unilaterally annexed by Russia in September 2022 in violation of international law — present very different profiles: Donetsk and Luhansk have been under full or partial Russian control since 2014, with an older collaboration infrastructure; Zaporizhzhia and Kherson are more recent occupations, with less established collaborator networks.

This difference in context is reflected in the profiles of those sanctioned. In regions under Russian control since 2014, collaborators have had twelve years to integrate into the occupation's administrative structure. In regions occupied since 2022, collaborators are often opportunists who quickly chose sides in the face of the occupier. Both categories are subject to sanctions — indicating that Kyiv makes no distinction based on the length of the collaboration.

The challenge of information recovery from occupied zones

How does Ukraine manage to identify and document collaborators in territories it no longer controls? The answer combines multiple sources: human intelligence networks maintained in occupied zones, testimony from people who fled to Ukraine or Europe, documents intercepted or recovered during partial territory liberations, and open sources (Russian social media, public records from the occupation administration).

Ukraine's Defense Intelligence Directorate (DIU) and Security Service (SBU) have devoted significant resources to this dual-use intelligence gathering: military and judicial. The same sources that allow military infrastructure to be targeted also document civilian collaboration networks. This is one of the least visible but most enduring dimensions of the intelligence war Ukraine is waging.

Transmission to international partners: a multiplier effect

From presidential decree to multilateral sanctions

Kyiv's decision to transmit information on the 67 sanctioned individuals to international partners transforms national decrees into a starting point for a multilateral process. This mechanism is well-established: since 2022, Ukrainian sanctions lists have fed into several rounds of EU, American, and British sanctions. The 15th EU sanctions package of December 2023, the 14th, the 21st currently under discussion — all have incorporated entities and individuals initially identified by Ukrainian services.

This coordination mechanism creates a considerable leverage effect. A Ukrainian sanction on an individual who has no assets in Ukraine can seem purely symbolic. The same sanction adopted simultaneously by the EU, the United States, and the United Kingdom freezes potentially substantial assets, bans travel, and sends a signal to correspondent banks worldwide. That is the chain that decrees 501/2026 and 502/2026 set in motion.

The Mayer Brown precedent: June 2026 sanctions

The law firm Mayer Brown published in June 2026 an analysis of recent developments in Russia-Ukraine sanctions, documenting the growing coordination between the Ukrainian and Western sanctions regimes. This coordination is not formalized in a treaty — it functions through information sharing, diplomatic consultations, and synchronized adoption of targeted measures.

The growing sophistication of this coordination indicates that Western partners have learned, over four years of war, how to transform Ukrainian intelligence into legal instruments usable in their own systems. This is not trivial: the standards of evidence in the European Union, the United States, and the United Kingdom differ, and administrative sanctions procedures have specific requirements. The fact that cooperation works despite these differences is an underappreciated institutional achievement.

The question of proportionality: who deserves to be sanctioned?

The line between survival and collaboration

The policy of sanctions against collaborators raises an uncomfortable question that nobody really wants to ask: how does one distinguish active collaboration from mere survival under occupation? Is a doctor who keeps working in an occupied hospital to treat local civilians a collaborator? A teacher who maintains classes so that the children on their street are not left without education?

Ukraine's answer — and it is defensible — rests on the distinction between passive and active acts. Continuing to do one's basic job to survive and serve the local population does not constitute sanctionable collaboration. Reorganizing a hospital to serve occupation forces as a priority, facilitating the transfer of children to Russia, providing meteorological services to military aviation — these acts are active, deliberate, and contribute directly to the Russian war effort or to the dispossession of the Ukrainian people.

The risks of political instrumentalization

Any individual sanctions policy carries a risk of political instrumentalization — using the lists to settle personal or political scores rather than to document genuine collaboration. This risk is real in Ukraine, as in any country engaged in prolonged war. The credibility of the accountability policy depends on the quality of the evidence and the transparency of the criteria applied.

At this stage, the concrete examples provided by Babel and other Ukrainian media on the profiles of the 67 sanctioned individuals suggest a selection based on documented activities, not political affiliations or personal grievances. But vigilance is warranted: in future sanctions packages, Ukrainian civil society and investigative journalists will have a crucial role to play in maintaining the rigor of the criteria.

Comparison with collaboration mechanisms in other conflicts

Historical precedents and their lessons

The question of holding collaborators accountable in occupied zones is not new in history. After World War Two, the Nuremberg trials established the principle of individual responsibility for war crimes — but they also revealed the limits of retrospective proceedings when documentation is fragmentary. One of the key lessons is that the more documentation is produced during the occupation — and not after — the more solid subsequent proceedings are.

In that sense, Ukraine's approach — actively documenting while the occupation continues — is more sophisticated than historical precedents. It draws on tools that the lawyers of 1945 did not have: satellite imagery, communications intercepts, Russian social media, commercial databases. These tools allow for mapping of collaboration at an unprecedented level of granularity.

The Bosnian model and its limits

The experience of the International Criminal Tribunal for the former Yugoslavia (ICTY) offers another instructive precedent. The ICTY documented and prosecuted war crimes perpetrators with partial success, but struggled to reach the lower echelons of the chain of command. Civilian collaborators — administrators, teachers, mayors — rarely appeared in indictments, for lack of sufficient evidence and due to procedural priorities.

Ukraine is drawing the lesson from that gap. By explicitly targeting institution directors, local company heads, and administrative officials of the occupation, decrees 501/2026 and 502/2026 signal a willingness to go further than the ICTY in documenting civilian responsibility. That does not guarantee that criminal proceedings will succeed — but it creates the documentary foundation for them to be possible.

The 67 in the context of the 21st EU sanctions package

A package under discussion, a Ukrainian list available

The 21st EU sanctions package against Russia was under active discussion at the time of the signing of the Ukrainian decrees in June 2026. This package, which includes measures against Russian transnational repression — surveillance of opponents in Europe, targeted assassinations, harassment of journalists — is also likely to incorporate entities from the Ukrainian lists of collaborators in occupied territories.

The coincidence in timing is probably not accidental. Ukrainian sanctions teams work in close coordination with European lawyers to synchronize announcements in a way that maximizes the impact of the measures. Publishing Ukrainian presidential decrees at the moment the European Council is discussing the 21st package allows pro-Ukraine delegations to feed fresh, documented data into the negotiations.

Finland and Nordic coordination

Among the most active partners in coordinating sanctions with Ukraine are the Nordic and Baltic countries. Finland, which shares a direct border of 1,340 kilometers with Russia and joined NATO in 2023, is particularly attentive to the accountability mechanisms for collaborators — a question that touches its own historical memory of Soviet occupation.

The Finnish Ministerial Committee on EU Affairs discussed the 21st package in detail at its session of June 26, 2026. The synchronization of these discussions with the publication of the Ukrainian decrees illustrates a level of diplomatic coordination that few modern wars have achieved between a belligerent and its non-belligerent allies.

Ukrainian sanctions as a domestic policy tool

A signal to Ukrainians in occupied zones

Decrees 501/2026 and 502/2026 are not only intended for international partners. They also send a message to those still living in occupied territories, to those who hesitate, to those calculating their risks. That message is twofold: on one hand, actively collaborating with the occupier leaves documented traces; on the other, Ukraine maintains its ability to identify and name its internal enemies, even hundreds of kilometers from its line of control.

For a population receiving fragmented information, often manipulated by Russian propaganda, the mere existence of these lists — accessible online, published in the Ukrainian press, discussed on social media — constitutes a form of resistance to erasure. These people do not live in the absolute impunity that Russian occupation would like to guarantee them. They are named, their acts are documented, and that documentation will cross the lines of occupation.

The risk of counter-productivity: not pushing the undecided toward collaboration

An overly aggressive policy of sanctions against collaborators can produce the opposite of the intended effect: if residents of occupied zones believe they will be sanctioned whatever they do, some might choose to collaborate more actively with the occupier to secure its protection rather than resist passively. This risk is real and Ukraine is aware of it.

That is why Zelensky's decrees target specific and documented acts — not general affiliations or residence in occupied zones. None of the 67 sanctioned individuals is on the list simply because they live or work in occupied territory. Each appears there for precise acts that directly contribute to the Russian war effort or to the dispossession of Ukrainians of their fundamental rights. That precision is not a weakness — it is the condition of legitimacy.

Next steps: toward a consolidated collaborator registry

A database under permanent construction

Decrees 501/2026 and 502/2026 are added to a list that grows regularly. Since 2022, Ukraine has sanctioned several hundred individuals and entities for collaboration with the occupier. These presidential decrees constitute the public, formalized component of a much larger registry maintained by Ukrainian security and intelligence services.

The ultimate objective is to create a consolidated database — shareable with international judicial partners in formats compatible with the required standards of evidence — that covers the full spectrum of collaboration acts since 2014. This colossal project is underway. It is never mentioned in press releases about weapons deliveries or diplomatic summits. But it may be one of the most enduring legacies of Ukrainian institutional resilience.

The role of investigative journalists in verification

In this process, Ukrainian media such as Babel, Ukrainska Pravda, Slidstvo.Info, and The Kyiv Independent play an irreplaceable role. They verify identities, contact sources, cross-reference data, and allow the public to distinguish between justified sanctions and possible errors. This investigative press operates under wartime conditions — under the threat of missile strikes, with offices sometimes destroyed — and still maintains verification standards that honor international journalism.

Babel's publication of the profile details of the 67 individuals sanctioned on June 26, 2026 is an example of this vital journalism. It not only informs the public but also creates external oversight of the sanctions policy — a function that democracies at war often struggle to maintain.

The impact on negotiations toward a possible ceasefire

Accountability as a precondition for peace

Some observers see the sanctions and accountability policies as an obstacle to peace — the argument being that a Russia fearing criminal prosecution of its nationals and collaborators will be less inclined to negotiate a ceasefire. This argument deserves serious examination, even if it is often advanced by those who would like Ukraine to accept a territorial freeze.

Ukraine's response — and it is consistent with historical precedents — is that impunity does not create lasting peace. It creates a fragile peace that collapses as soon as the balance of power shifts, because it does not resolve the fundamental violations of rights and international law. The documentation of collaboration, the sanctions, the criminal proceedings are not obstacles to peace: they are the conditions for a peace that lasts.

What the 67 names say about the state of the war

In the end, the very existence of these 67 names says something about the state of the war in June 2026. They indicate that after more than four years of occupation, Ukraine maintains an intelligence and documentation capability in territories it does not physically control. They indicate that Kyiv is already thinking about the post-war period, about recovering its territories, about rebuilding a society capable of living with its scars.

And they indicate that Zelensky, in signing these decrees amid the daily urgencies of war, chooses not to forget. Not to let collaboration fade into the oblivion of chaos. That choice — institutional memory as a weapon — may be one of the most strategic ones he has made.

Conclusion: the war of registries, as long as the war of trenches

An accountability doctrine built for the long haul

Decrees 501/2026 and 502/2026 will not settle the war in Ukraine. They will not liberate occupied territories. They will not bring back deported children. But they are part of a legal and documentary edifice that Ukraine is building stone by stone, since 2014 and with heightened intensity since 2022. An edifice that will serve to build real peace when the moment comes — not a peace of capitulation, but a peace of justice.

This war of registries will be as long as the war of trenches. It will receive less media coverage, less funding from partners, less visibility in opinion polls. But it is just as indispensable. And the 67 names of June 26, 2026 are the latest proof of that.

What the West must do with this information

Ukraine's Western partners now hold fresh, documented data on 67 individuals and entities who chose to collaborate with the Russian occupier. The ball is in their court. They can integrate this data into their next sanctions packages, transmit it to their international prosecutors, or preserve it for a future judicial proceeding.

What they cannot do, without betraying the spirit of their support for Ukraine, is ignore this information on the grounds that it comes from a country at war. International law does not distinguish between evidence according to which side produces it. It distinguishes according to quality, reliability, and relevance. And on those criteria, decrees 501/2026 and 502/2026 deserve serious attention.

By Maxime Marquette, columnist

Columnist's transparency note

Sources and method

This article is based on information published by Babel Ukraine concerning decrees 501/2026 and 502/2026 by President Zelensky, as well as analyses by Mayer Brown concerning Russia-Ukraine sanctions for June 2026. Information on the specific profiles of sanctioned individuals (Prylipko, Andros, Soyuzmetalservice) comes from data available in these primary sources. No testimony was invented or attributed without a documented source.

Editorial position

This decoding is pro-Ukrainian in its orientation, in keeping with MadMax's editorial doctrine. It does not claim artificial neutrality between an aggressor state and a state that is the victim of illegal occupation. The doubts and nuances expressed on certain aspects of the sanctions policy (risk of counter-productivity, political instrumentalization) reflect an effort at analytical rigor, not a moral equidistance between the parties.

Sources

Primary sources

Babel Ukraine — Ukraine imposes sanctions against 67 collaborators in occupied territories — June 26, 2026

Mayer Brown — Russia/Ukraine Sanctions Update, month of June 2026 — June 26, 2026

Finnish Government — Ministerial Committee on EU Affairs discusses 21st EU sanctions package — June 26, 2026

Secondary sources

Defend Lawyers — Russia stages international terrorism trial against three Kherson men — June 22, 2026

JusticeInfo — The Special Tribunal for the Crime of Aggression enters its skeleton phase — June 26, 2026

Kyiv Independent — Skelia assault regiment commander suspended amid investigation into alleged abuse — June 25, 2026