Section 4. Before you proceed: key risks, mitigation and deal breakers

Section 4. Before you proceed: key risks, mitigation and deal breakers


Section 4. Before you proceed: key risks, mitigation and deal breakers

Before engaging with any opportunity in Ukraine, it is essential to assess whether your intended approach is viable, manageable and executable in the current context.

This section serves as a pre entry decision filter.

It highlights the key risks that must be addressed, the tools typically used to mitigate them, and the deal breakers that should trigger a pause or exit.

Detailed reference materials are provided in the annexes.

Operating environment and security

Ukraine operates under conditions of ongoing war, with significant regional and sectoral differences.

Key risks

  • Physical damage to assets and infrastructure
  • Disruption of operations and logistics
  • Regional security constraints

How risks are typically mitigated

  • Careful selection of locations outside active combat zones
  • Political and war risk insurance (where available)
  • Contractual protections (force majeure, step in rights, risk sharing)

Deal breakers

  • Project or asset located in an active combat or occupied area
  • Inability to obtain any form of risk coverage or mitigation

See Annex B1. Valuation of war damage; recovery and reconstruction needs;

Annex D. Regulatory Frameworks, Security and Compliance.

Payment, currency and financial exposure

Commercial success depends not only on demand, but on how payment and financial risk are structured.

Key risks

  • Delayed or non payment
  • Currency controls and transfer restrictions
  • Dependence on weak or uncertain payers

How risks are typically mitigated

  • Donor  or IFI funded payment structures
  • Guarantees, escrow mechanisms or advance payments
  • Milestone based payment schedules

Deal breakers

  • Unclear or unsecured source of payment
  • Refusal to provide any form of payment security

See Annex D3. Currency limits and restrictions;

Annex F. Financial and State Support Programmes.



Section 4. Before you proceed: key risks, mitigation and deal breakers

Legal, regulatory and compliance constraints

Ukraine’s legal framework is broadly aligned with European standards, but practical implementation requires careful navigation.

Key risks

  • Regulatory changes under martial law
  • Administrative delays and procedural complexity
  • Sanctions, AML and compliance exposure

How risks are typically mitigated

  • Early legal and regulatory screening
  • Full disclosure of ownership and beneficiaries
  • Compliance aligned with IFI / EU standards

Deal breakers

  • Links to sanctioned persons or jurisdictions
  • Nontransparent ownership structure
  • Inability to obtain mandatory permits or approvals

See Annex D. Regulatory Frameworks, Security and Compliance.

Counterparties, project readiness and risk structuring

Many opportunities fail not due to lack of demand, but due to weak counterparties or immature projects.

Key risks

  • Counterparty without decision making authority or capacity
  • Projects visible politically but not ready to transact
  • Unallocated or unmitigated risk

How risks are typically mitigated

  • Counterparty due diligence and governance checks
  • Verification of project preparation stage
  • Use of guarantees, insurance and risk sharing instruments

Deal breakers

  • No accountable project owner or sponsor
  • Absence of basic project preparation
  • Inability to structure risk in any acceptable form

See Annex E. Investment and Opportunity Ecosystem.

When to pause or walk away

You should pause or reconsider engagement if:

  • the source of payment cannot be secured;
  • ownership, control or delivery responsibilities remain unclear;
  • the counterparty lacks authority or credibility;
  • key risks cannot be mitigated or shared.

Walking away early is often a rational decision, not a failure.

Opportunities should be filtered before they are pursued.

Risks ignored early become costs later.


Counterparties, project readiness and risk structuring