Currency restrictions on individuals

05.10.2022

On the day of the beginning of Russia's armed aggression against Ukraine - 24 February 2022 - the National Bank of Ukraine (NBU) adopted Resolution № 18 ("Resolution") to ensure the secure and stable functioning of the country's financial system during the war.  

The Resolution (as amended), inter alia, stipulates restrictions applicable to natural persons’ operations with local and foreign currency, as well as on their bank accounts. Main restrictions concerning natural persons can be summarized as follows: 

  • Cash  may be withdrawn from UAH accounts in the amount of up to UAH 100,000 per day (in Ukraine) and up to the equivalent of UAH 12,500 per every 7 days (outside of Ukraine). No limit applies to withdrawals in Ukraine of salary, social payments, and withdrawals in the bank branches situated in the local communities within the area of ​​military (combat) operations, or under temporary occupation or encirclement (blockade) (hereinafter - "Dangerous Territories")[1], and abroad - by the staff of military attaches and representatives of the Ministry of Defense of Ukraine at foreign diplomatic missions of Ukraine (“Military Staff”). 

  • Cash from the foreign currency accounts may be withdrawn in cash in the amount of up to the equivalent of UAH 100,000 per day (in Ukraine as well as abroad). No limit applies to withdrawals in Ukraine by any client in the bank branches situated at the Dangerous Territories. Restrictions on cash withdrawals abroad do not apply to the Military Staff. 

  • Foreign currency may be sold to the banks - in cash and cashless form, and to non-banking institutions and Ukrposhta - in cash. On April 14, 2022, the NBU allowed the banks to sell to individuals the surplus of foreign currency cash which they receive from FX transactions. Individuals can also purchase non-cash foreign currency in an amount not exceeding the equivalent of UAH 100,000 per calendar month to place a deposit with the same bank for a period of at least three calendar months without the right to early termination. Such purchased currency can be credited to the deposit account without prior crediting to the current account of an individual. In particular, natural persons can purchase non-cash US dollars for hryvnias placed in a current account at the official NBU exchange rate at the time of purchase with subsequent placement of the purchased currency on deposit account for a period of at least 6 calendar months without the right to top up the deposit and without right of early contract termination; after the expiration of the period, the deposit together with accrued interest is subject to return in hryvnias at the official NBU exchange rate at the time of return. Bank metals (with physical delivery) may also be purchased in the bank branches (with some restrictions). Apart from that foreign currency may be purchased for carrying out the operations which are permitted according to the Resolution (see below). 

  • Cross-border transfers from Ukraine suspended. Exceptions that may be relevant to individuals include payments for import of goods stipulated by the Resolution of the CMU “On certain issues related to ensuring import” No.153 dated 24 February 2022 (provided that the supply of goods is after 23 February 2021), payments for medical services abroad, as well as related transportation and repatriation (including related payments of insurers), payments for education abroad, and payments to certain international financial institutions.  

  • Residents are free to spend electronic payment means (e.g. cards/tokens) abroad for payments for goods, works and services, in the amount of up to UAH 100,000 per calendar month from local currency accounts, and without limits - from foreign currency accounts.. The NBU has vested the banks with a discretion not to apply such restrictions to individuals who carry out volunteering activities in the case of the purchase of certain categories of goods subject to certain conditions: (i) operations on the volunteer's account are typical for this individual and the volume of operations carried out on the volunteer's account/accounts exceeded UAH 100,000 per calendar month before July 21, 2022; (ii) submission to the bank of a letter from a state body/military unit regarding cooperation with the volunteer and ordering goods of respective purpose, if the amount of such operation/operations per calendar month exceeds the equivalent of UAH 400,000, (iii) provision of an estimated cost (calculation) of goods and the terms of order fulfillment; (iv) the volunteer must inform the bank about the collection of funds for the purpose of payments. The bank may discontinue carrying out operations which exceed the above amount in case it has obtained information from open sources regarding the unfair practices of the said volunteer. 

  • Payments on the basis of a specific permit from the NBU are allowed. 

  • p2p transfers between individuals, on their foreign currency bank cards, have been limited to the equivalent of UAH 100,000 per month, and on local currency cards – prohibited (since 5 October 2022). Quasi-cash transactions (purchase of cryptocurrency, replenishment of e-wallet / brokerage / forex accounts, cashing of traveler’s checks / payments to betting companies, purchase of gift cards etc.) may be carried out within the same limit, but only out of the funds available at foreign currency accounts. 
    On specifics of payments under contracts please see section Payments under contracts

  • Official exchange rate was fixed at 29,25 Hryvnias for 1 USD from 24 February 2022 till 20 July 2022, and from 21 July 2022 – at UAH 36.5686. The official exchange rate of Hryvnia to other foreign currencies and special drawing rights is to be set, and the book price of bank metals is to be calculated, by the NBU based on the UAH-USD cross-rate. The price of purchase and sale of foreign currency cash may be determined by the bank. 

  • No cards/tokens (electronic payment means) issued by the participants of international card payment systems operating in Russia and Belarus shall be accepted in Ukraine, and no funds may be credited to the accounts of Ukrainian residents from such cards/tokens [2]. 

  • Purchase and sale of cryptocurrency are possible within the limits set by the NBU. 
     

The NBU has also ordered that commercial banks operate their branches and replenish cash in ATMs in usual mode. No limitations apply to cashless payments. The amount of cash foreign currency that banks can offer to individuals will include the entire amount of non-cash currency purchased by banks since 13 April 2022, not half of it as was established until September 5, 2022. 
 

For other restrictions, in particular those on legal entities, see the answer to question Currency restrictions for business

 

 

[1] See Order of the Ministry of Reintegration of the Temporarily Occupied Territories of Ukraine No. 75 dated 25 April 2022 "On Approval of the List of Territorial Communities Located in the Area of ​​Military (Combat) Operations or Under Temporary Occupation, Encirclement (Blocking) as of June 29, 2022 » - https://zakon.rada.gov.ua/laws/show/z0453-22#n4.

[2] According to the NBU, a number of international payment systems, such as Visa, Mastercard, American Express, JCB and PayPal, have already expressed their principled position in support of Ukraine and publicly announced termination of cooperation with banks in Russia. Source: https://bank.gov.ua/ua/news/all/nbu-zaklikav-china-unionpay-ta-unionpay-international-viyti-z-platijnogo-rinku-rf 

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Igor Krasovskiy 

Partner, Banking and Finance 

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Partner, Banking and Finance