Banking, FX and Payment Restrictions Caused by the declaration of Martial Law in Ukraine


On 24 February 2022, the National Bank of Ukraine issued guidance on the conditions of the banking system’s operation and foreign exchange market’s functioning under martial law (the Resolution).

These actions by the NBU aim to ensure the unfailing and steady functioning of the country’s financial system, maximum support for the Ukrainian Armed Forces, and the uninterrupted operation of critical infrastructure facilities.

In view of the imposition of martial law in Ukraine, the following temporary restrictions have been introduced:

  1. The operation of the Ukrainian currency market is suspended, except for transactions involving sales of foreign currencies.
  2. The issuance of e-money, replenishment of electronic purses with e-money, and the dissemination of e-money is suspended.
  3. Debit operations on the accounts of residents of the Russian Federation by its servicing banks are terminated.
  4. The official UAH exchange rate has been fixed as of 24 February 2022.
  5. Cash withdrawals from individual client accounts are limited to UAH 100,000 per day, and cash from clients’ accounts in foreign currencies is restricted.
  6. A moratorium on cross-border currency payments has been introduced.
  7. The execution of debit transactions by servicing banks on the accounts of the residents of the Russian Federation has been stopped.

These restrictions do not apply to enterprises and institutions providing mobilisation plans (tasks) and the Government of individual approvals by the NBU.

The Resolution also provides for the following measures:

  1. banks must ensure uninterrupted operation, taking into account the restrictions defined in this Regulation, and provide access to safe deposit boxes in an uninterrupted manner;
  2. there are no limitations on non-cash payments;
  3. ATMs are backed by cash without restrictions;
  4. the NBU performs cash backing without limitations;
  5. the NBU performs blank refinancing for banks to maintain liquidity without limitations on the amounts for up to one year, with an extension possibility for one more year;
  6. payments by the Government of Ukraine will be made without limitation for the period of the special legislation.

Legislation: NBU Regulation No. 18 on 24 February 2022 “On the functioning of the banking system under martial law”