
Abstract: The paper examines the legal challenges and normative conflicts arising from the application of asset freezing regimes to participants in public-private partnership (PPP) contracts. It analyzes the tension between restrictive measures and the pacta sunt servanda principle, particularly in the context of Ukraine’s infrastructure recovery projects. The study explores the distinction between asset freezing and confiscation under Council Regulation (EU) No 269/2014 and the implications of the OFAC "50 Percent Rule" for corporate structures. Special attention is given to the mechanism of derogations under Regulation (EU) No 833/2014 and the necessity of establishing temporary trust management for frozen assets within PPP frameworks to ensure the continuity of critical infrastructure projects. Keywords: public-private partnership, PPP, sanctions, asset freezing, Ukraine, European Union, OFAC, 50 Percent Rule, infrastructure projects, legal regime, derogation. Source citation: Kyryliuk, D. V. (2026). Legal regime of assets of sanctioned entities in public-private partnership projects. Innovative Development of Society: Science, Law and Technologies in the Era of Digital Transformation: Proceedings of the International Scientific and Practical Conference (Kyiv, March 20–21, 2026) / NGO “Institute of Innovative Education”; Scientific and Educational Center of Applied Informatics of the National Academy of Sciences of Ukraine. – 2nd ed., rev. and enl. – Kyiv–Zaporizhzhia: AA Tandem, 2026. pp. 70–72. ISBN: 978-966-488-352-5
public-private partnership, derogation, infrastructure projects, OFAC, sanctions, asset freezing, European Union, legal regime, Ukraine, 50 Percent Rule
public-private partnership, derogation, infrastructure projects, OFAC, sanctions, asset freezing, European Union, legal regime, Ukraine, 50 Percent Rule
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