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On the work of the banking system during martial law

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On February 24, 2022 the National Bank of Ukraine adopted the Resolution of the Board № 18 of February 24, 2022 "On the operation of the banking system during martial law" to ensure reliable and stable functioning of the country's financial system and maximize the Armed Forces of Ukraine, as well as uninterrupted critical facilities. infrastructure, which introduced a number of temporary restrictions to ensure the stable operation of the financial system.

This Resolution stipulates that banks ensure the uninterrupted operation of branches in the absence of danger to life and health. Detailed information on the work of branches of each banking institution can be found on their official resources.

It also provides the following steps:

• Limit cash withdrawals from the client's account in the amount of UAH 100,000 per day (excluding salaries and social benefits), except for enterprises and institutions that ensure the implementation of mobilization plans (tasks), the Government and individual permits of the National Bank of Ukraine without accrual and withdrawal commissions.

• Make non-cash payments without restrictions.

• Make payments to the Government without restrictions under the legislation on the special period

• Provide access to safe deposit boxes uninterruptedly. 10.

• The NBU refinances banks to maintain liquidity without restrictions in the amount of up to 1 year with the possibility of extension for another year.

• Record the official exchange rate on February 24, 2022

• Introduce a moratorium on cross-border foreign currency payments (except for enterprises and institutions that ensure the implementation of mobilization plans (tasks) and the Government, certain permits of the NBU)

• Stop the implementation of expenditure operations by servicing banks on the accounts of residents of the state that carried out the armed aggression against Ukraine.

Resolution in Ukrainian and English.

The NBU is constantly updating this Resolution, with all updates as of March 8, 2022 can be found at the link.

From March 1, 2022, instead of a total ban on the issuance of cash from the client's foreign currency account, a limit of up to UAH 30,000 per day has been imposed. In addition, the National Bank of Ukraine has relaxed a number of bans on foreign currency transactions. in foreign and national currency outside Ukraine, except in cases of implementation:

• banks' own operations, including settlements with international payment systems. Settlements on documentary and reserve letters of credit / guarantees / counter-guarantees opened (confirmed, provided) from February 24, 2022 are prohibited, except in cases when such settlements are made for the purpose of conducting operations of bank clients specified in subparagraphs 2-6 of paragraph 14 of the Resolution;

• import operations of residents on the purchase of critical import goods according to the list approved by the Cabinet of Ministers of Ukraine;

• MFI foreign exchange transactions, including MFI offices, as well as foreign exchange transactions of residents and non-residents on the transfer of funds in foreign / national currency for settlements with the MFI or its representative office;

• foreign exchange transactions by residents and non-residents to carry out mobilization and other measures (needs) defined by the laws of Ukraine governing relations in the areas of national security and defense;

• operations to pay for medical expenses in foreign medical institutions, to pay for the transportation of patients, to pay for the death of citizens abroad (transportation and funeral expenses);

• on the basis of separate permits (decisions) of the National Bank of Ukraine, adopted on the basis of appeals of the Cabinet of Ministers of Ukraine, ministries and other state bodies of Ukraine;

• transfers in favor of diplomatic missions, consular posts of Ukraine abroad.

• settlements abroad using electronic means of payment or using electronic means of payment to obtain cash.

Banks carry out operations on purchase and sale of foreign currency on behalf of clients:

• in US dollars - at the official exchange rate of the National Bank of Ukraine, effective on the day of the transaction;

• in other foreign currencies - at the exchange rate determined on the basis of the official exchange rate of hryvnia to the US dollar, effective on the day of the transaction, as well as information on current foreign exchange rates to the US dollar (or US dollar to foreign currencies) in international foreign exchange markets , which are obtained through trade information systems at the time of the transaction.

The list of critical import goods, for the payment of which a special procedure for the purchase of foreign currency is provided, is determined by a resolution of the Cabinet of Ministers, which is constantly updated by the Cabinet of Ministers. In order to ensure proper conditions for the purchase of foreign currency and remittances for the purchase of critical import goods, banks have established joint ongoing work with customers. In particular, banks regularly inform customers about the ac a list of critical import goods and analyze import transactions for compliance of the purchased goods with the criteria listed above.

The Cabinet of Ministers also temporarily allowed the population to use some seized bank accounts. The relevant decision is enshrined in Government Order №198 of March 2, 2022: in order to ensure the livelihood of the population in martial law to allow individuals to carry out expenditure operations from accounts seized by state executive service, private executors, without such arrest provided if the amount of recovery under the executive document for such a person does not exceed 100,000 (one hundred thousand) hryvnias.

Responding to questions about loan servicing, the NBU said it had allowed banks to disregard defaults on loans as arrears during wartime and 30 days thereafter if defaults were related to Russian aggression.

But draws attention to the fact that:

• Credit vacations should be agreed directly with the bank. However, if borrowers have sufficient resources to continue to operate and service loans, they should continue to pay.

• Credit vacation is a deferral of debt payment, not forgiveness. Credit vacation is just a break, ie a delay in the client's settlements with the bank during martial law in the country. Such a "break" may relate to the payment of the principal amount of the loan (the "body" of the loan) or accrued interest.

• The agreement between the bank and the borrower is voluntary. Many banks have already initiated the deferral of payments on loans, this information is available on their official websites. If the client feels that due to falling incomes "does not pull" the loan, you should contact the bank.

• Credit vacations do not reduce the amount of your debt. The credit vacation option does not reduce the amount of debt. The possibility of deferral of payment of the principal amount of the loan or accrued interest on the loan depends on the proposals of a particular bank.

Contact your banking institution for additional details and conditions.

The National Bank and the banking system of Ukraine will continue to work together and jointly defend the financial system of Ukraine.