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Ukraine Eases War-Time FX Controls: Syndicated Loans Servicing, Dividends Repatriation, Forward FX, and Military Support Incentives

The National Bank of Ukraine (NBU) introduced further liberalisation of currency restrictions introduced under martial law. These amendments are set out in NBU Resolution No. 95 dated 5 August 2025, effective from 6 August 2025. Below is a summary of the key developments:

1. Syndicated Loans with IFIs Exempted from Key FX Limits

The NBU has allowed Ukrainian borrowers to service foreign loans granted by a syndicate of lenders that includes a foreign bank and at least one international financial institution (IFI). The new exemption has eased the servicing of loans to foreign banks participating in the financing, provided they have a credit rating of “A” according to Standard & Poor’s” or Fitch Ratings / “A2” according to Moody’s Investors Service.

Such syndicated financing will no longer be subject to the following limitations:

• limit on the maximum interest rate of 12% (including interest, contingent fees, and other payments, but excluding principal);
• prohibition on early repayment, whether voluntary or on demand (provided that the loan is extended after 20 June 2023);
• requirement that disbursement should be made only to a local account of the borrower and only after 20 June 2023; and
• requirement for a local borrower to service the loan exclusively from its own FX reserves during the first year of maturity (i.e., local currency reserves may not be converted into FX to service the loan).

The foregoing requirements remain applicable to loans from other lenders.

2. Repatriation of 2023 Dividends Allowed

The NBU now allows the repatriation of dividends accrued from 1 January 2023, within the existing monthly limit of EUR 1 million (or equivalent) per legal entity. Previously, dividend repatriation was permitted only for profits earned from 1 January 2024.

3. Forward FX Transactions for Import Hedging

Ukrainian legal entities and individual entrepreneurs may now enter into forward FX contracts with Ukrainian banks to hedge currency risk associated with imports of goods. The transactions must involve physical delivery of the underlying currency. This is the first easement for forward FX instruments for non-financial companies since the introduction of martial law.

4. Early repayment by debt-to-equity conversion

The NBU has permitted early repayment (whether voluntary or upon demand) of loans previously restricted from such repayment, by converting the loan into equity.

5. Incentives for Businesses Supporting the Armed Forces

The NBU has introduced a mechanism enabling businesses to exceed existing cross-border transfer limits in proportion to their contributions to support the Ukrainian Armed Forces. Resident legal entities may conduct generally restricted cross-border transactions, such as dividend payments, loan repayments or capital transfers, up to the amount donated (in any currency) to the NBU’s special account for military support after 7 August 2025.

For tailored guidance, please contact Olexiy Soshenko or Olesia Mykhailenko.