Bank Transactions Under Martial Law
The Russian Federation’s war against Ukraine, in addition to the obvious consequences, caused several changes and restrictions in the banking system of Ukraine. Some types of transactions that used to be quick and easy got restricted after the full-scale invasion started. Accountor Ukraine will help you understand which bank transactions are allowed today, and which are prohibited.
The Resolution of the National Bank of Ukraine # 18 of 24.02.2022 "On the operation of the banking system under martial law" contains relevant information regarding currency and other payments.
It should be noted that the restrictions are somewhat less strict for organizations ensuring the implementation of mobilization plans, for those having representative offices in other countries, those involved in social programs / projects of international financial organizations, as well as for a number of state bodies, diplomatic missions, customs and specialized financial institutions.
For Most Companies (as of May 2024):
The limit of UAH 100,000.00 per day applies both to withdrawals of funds in national currency and to withdrawals of their equivalent in foreign currency. Outside of Ukraine, cash from the accounts in UAH can be withdrawn in an amount not exceeding UAH 12,500.00 per every 7 calendar days.
Financial aid payments from international humanitarian organizations for certain categories of citizens are allowed in an amount not exceeding UAH 50,000.00 per day per one recipient.
Cashless settlements in UAH can be made without any restrictions.
Selling foreign currency can be carried out as usual, whereas purchasing foreign currency is possible only under certain conditions and with proper notification regarding the intended use of the funds.
First and foremost, bank clients must fulfill obligations under existing unfinished agreements using the funds in their own foreign currency (current or savings) accounts.
In general, it is prohibited to carry out cross-border transfers in foreign currency from Ukraine/transfer of funds to correspondent accounts of non-resident banks in UAH/foreign currency in resident banks. However, paragraph 14 of Resolution 18 lists the cases when such transfers are allowed.
Let us look at the cases when cross-border transfer is allowed:
- Per diems for international business travel;
- fulfillment of obligations under forward contracts;
- treatment in medical institutions of a foreign country;
- studying abroad;
- paying alimony and child support
- payment of reinsurance premiums;
- settlements under leasing and rental contracts;
- payment of interest on bank loans.
It is also allowed to purchase and transfer foreign currency or UAH abroad for payments for the import of any goods/products/services/works, provided that the delivery for such transactions was made after February 23, 2021.
On a separate note, we would like to emphasize that it is now possible to pay "new" dividends to non-resident founders. "New dividens" means dividends based on the results of operations for the period from 01.01.2024, and they will have a limit specified in the "E-limit" system.
However, it is prohibited to pay dividends for the previous periods.
Така сама ситуація з виплатою частки статутного капіталу засновнику-нерезиденту у випадку ліквідації підприємства. The same applies to paying a share of the authorized capital to a non-resident founder in the event of company liquidation.
Transactions are prohibited if the payments are directly or indirectly related to the Russian Federation or the Republic of Belarus.
Gradually, currency restrictions are going to be abolished, and certain legislative acts have already introduced some relaxations. In early May, the largest liberalization package since the beginning of the full-scale war was implemented.
With this in mind, we advise you to stay calm and wait for more relaxatations to come. Meanwhile, we at Accountor Ukraine will keep you updated on the latest legislative changes.
