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Overview of Martial Law Currency Restrictions | Briefing note

Due to the introduction of martial law in Ukraine, the National Bank of Ukraine (NBU) has implemented significant restrictions on cross-border payments. These measures are set out in NBU Resolution No. 18, which came into effect on 24 February 2022.

This briefing note is a comprehensive overview guide designed to equip you with the knowledge needed to navigate Ukraine’s evolving currency control regime under martial law.

The publication is intended to provide legal and compliance teams, investors, and financial institutions with a structured overview of the applicable restrictions under Ukrainian law during martial law – including special provisions for IFIs, DFIs, syndicated loans, and dividend repatriation.

Key Topics Covered

• Regulatory basis and general prohibition on cross-border payments
• Overview of exemptions (IFIs, DFIs, ECAs, syndicated loans, intra-group financing, etc.)
• Dividend and lease payment restrictions
• Enforcement actions, guarantees, and insurance considerations
• Import/export rules and settlement deadlines
• Investment-related and military support-linked permissions
• NBU individual permit regime

Click the button below to read the full briefing note and gain a deeper understanding of how these changes impact your business and legal strategies.