As Ukraine enters another year of full-scale war, the authorities continue to deploy targeted measures to stabilise the economy, attract private capital and prepare the groundwork for post-war recovery. This update covers (i) the latest operational developments for the U.S.–Ukraine Investment Fund (the “Fund”) and (ii) further easing of the martial-law moratorium on select cross-border FX transfers by the National Bank of Ukraine (the “NBU”), effective January 14, 2026.
U.S.–Ukraine Investment Fund: From Set-up to Intake and Screening
The Fund has moved beyond the institutional stage to early deal origination. In January 2026, an online portal was launched for submitting investment proposals, enabling companies and investors to propose projects in priority sectors such as critical minerals, energy, transport, ICT, and advanced technologies. Initially, the Fund prioritises equity and quasi-equity instruments to attract private capital and generate a multiplier effect, rather than providing standalone funding.
Public updates indicate the initial intake was substantial, with more than 60 submissions in the first month, including 37 from Ukrainian companies. The review process is active: one project is undergoing due diligence, while others are at different stages. After a first assessment in January, 22 projects moved forward. Details are expected to remain confidential until preliminary checks are done.
The Fund’s governance comprises a Board and four committees (investment, audit, administrative, and project sourcing). The project sourcing committee meets monthly, with assessment results of the initial pipeline due to be presented to the investment committee and the Board by March 2026 for final financing decisions.
The initial capital is reported at USD 150 million (USD 75 million each from Ukraine and the US), with additional funds from licence-related proceeds and other designated revenue streams. Officials aim to sign the first three investment agreements by the end of 2026, providing market participants with clearer timelines and process insights.
NBU Easing of Select FX Restrictions through a Loan-linked Payment Limit
Effective January 14, 2026, the NBU allows foreign currency from non-IFI loans received on or after January 1st, 2026 to be used as a payment limit for certain restricted transactions.
A key constraint is the “aggregation” effect: the loan-linked payment limit is single, aggregate, and self-reducing. Any amount used for permitted payments reduces later principal repayments abroad under the same new loan. This affects principal only; interest remains payable based on the full outstanding principal.
Illustration: if a company takes a EUR 10 million foreign loan after January 1st, 2026, and uses EUR 3 million of it to pay dividends above the monthly cap, only EUR 7 million can be repaid cross-border later. The remaining EUR 3 million is effectively locked in Ukraine as long as wartime FX restrictions stay in place, though interest can still be paid on the full EUR 10 million.
In practice, this route is likely relevant only in narrow cases, such as refinancing pre-war Eurobonds and other overdue liabilities, where near-term principal repayment under the new refinancing instruments is not expected.
Material prepared by Olexiy Soshenko, Managing Partner, and Artem Mykhailyk, Associate, for the 10th edition of LIR Ukraine (page 34).