Currency limits and restrictions
At the beginning of the full-scale invasion, the National Bank of Ukraine (the NBU) and defined a series of currency restrictions to stabilize the financial system’s operations. However, as of May 13, 2024, some of these restrictions have been relaxed or completely removed. Below is a non-exclusive list of the limits and restrictions that remain in effect in Ukraine.
- The deadline for settlement of export and import transactions over UAH 400,000 (≈ USD 9,588) is limited to 180 calendar days and applies to transactions carried out from 05.04.2022. The term of 365 days applies to transactions carried out before 05.04.2022.
- Dividends: Ukrainian residents are now allowed to remit abroad dividends earned from their business activities starting from 1 January 2023. Such transfers can be made up to the established monthly limit of EUR 1 million and must comply with other conditions specified by the NBU.
- “Old” cross-border loans: Interest on loans received before June 21, 2023, that was due between February 24, 2022, and April 30, 2024, can be paid up to EUR 1 million (or its equivalent) per calendar quarter. Interest on these loans due after April 30, 2024, can be paid without any monetary limitations.
- “New” cross-border loans: permitted to repay foreign loans within the first year using only own foreign currency funds, then purchasing is allowed. Interest and other loan-related fees can be paid with both owned and purchased foreign currency. The interest rate must not exceed 12% annually.
- Financing of branches of representative offices abroad is possible provided that transfers are made: (a) during the current calendar year within the total amount of funds transferred by the resident during 2021 for the maintenance of its branches, representative offices (no more than 1/4 of this amount may be transferred within one calendar month); and (b) at the expense of the resident legal entity's own funds in foreign currency; and (c) through one bank, and (d) only for covering the branches' operational expenses.
- Representative offices of international card payment systems and foreign airlines are allowed to transfer up to EUR 5 million (or its equivalent) per month to their parents.
- Cash: issuance of cash in foreign currency has a daily limit of UAH 100,000 (or its equivalent ≈ USD 2,397), except in certain cases.
- State-owned companies will be able to purchase and transfer foreign currency in favor of nonresidents to buy emission quotas to cover or compensate for carbon dioxide (СО2) emissions associated with aviation activities.
- Since September 6, 2024, the NBU has set a monthly limit of an equivalent of UAH 100,000 (≈ USD 2,397) for payments to FX accounts abroad using payment cards issued by Ukrainian banks, for transactions under merchant category codes 5094 (precious stones, metals, and jewelry), 5944 (watches, jewelry, and silverware), and 5972 (stamp and coin stores). This limit is in line with the general limit set by the NBU for payments abroad using payment cards issued by Ukrainian banks to accounts in the domestic currency.
- Starting from August 6, conditions are created for converting a resident borrower’s external loan into equity: a non-resident creditor may transform the borrower’s debt into a contribution to its charter capital through a set-off of mutual claims.