On02 July 2014 the Cabinet of Ministers of Ukraine adopted Order “On issuesregarding state registration of property rights to the immovable property whichis located on the temporary occupied territory” No.226 (the “Order”). The Ordercame into force on 09 July 2014.

Accordingto the Order, state registration of proprietary rights to immovable propertylocated on the territory of Autonomous Republic of Crimea and the city ofSevastopol (the “CrimeanImmovable Property”) shall be performed by the departments ofthe state registration service in Kharkiv and Zaporyzhzhya regions.

Wenote that under the general principles, state registration of proprietaryrights to immovable property in Ukraine is performed at the location of suchproperty by the local departments of the state registration service of Ukraine(the “RegistrationService”) and the proprietary right only becomes valid uponregistration. However, due to the pending occupation of the Autonomous Republicof Crimea and the city of Sevastopol (the “Occupied Territory”) the departments ofRegistration Service located in the Occupied Territory are not able to performstate registration. This particular issue was initially raised in the law “OnProcurement of Rights and Freedoms of Citizens of Ukraine on the OccupiedTerritories” as of 15 April 2014 No.1207-VII (the “Law”) which instructedthe Cabinet of Ministers of Ukraine to authorise the departments of theRegistration Service located outside of the Occupied Territory to perform stateregistration of proprietary rights to Crimean Immovable Property.

Authors:

NataliaKushniruk, Senior Associate,natalia.kushniruk@cms-cmck.com

YuliyaZemskova, Associate, yuliya.zemskova@cms-cmck.com