Ukraine Continuously Eases Currency Transfer Rules: Key Changes for Businesses and Investors

With the introduction of martial law in Ukraine on February 24, 2022, the National Bank of Ukraine (the “NBU”) implemented strict currency restrictions, primarily governed by NBU Resolution No. 18 of February 24, 2022, On the Operation of the Banking System Under Martial Law. Among the key measures was a moratorium on cross-border currency transfers.

Since then, the NBU has steadily dismantled many of these measures. Most business-related transfers are now possible, though strict conditions still apply depending on the transaction type.

Dividend Payments

Repatriation of dividends remains one of the key concerns for foreign investors, as it directly affects their ability to recover returns on capital and influences overall confidence in Ukraine’s investment climate. 

Currently, dividend payments abroad for corporate rights/shares are permitted, subject to the simultaneous fulfilment of the following conditions: 

• dividends must be accrued for the period starting January 1, 2023 (excluding payments from undistributed profits from previous periods or reserve capital);
• funds must be transferred by the issuer of the corporate rights/shares directly to the accounts of foreign investors/non-residents abroad and/or through Ukraine’s depositary system;
• the monthly transfer limit of the equivalent of EUR 1 million must not be exceeded, and transfers must be processed using the NBU’s “E-Limits” system;
• the issuer of the corporate rights/shares must have been operating for at least one year as of the transfer date;
• the foreign investor/non-resident must have owned the corporate rights/shares for at least six months as of the transaction date. 

In addition, specific requirements apply to dividend payments related to Eurobonds.

Repayment of Loans/Credits and Interest

Currently, different requirements apply to the repayment of cross-border loans/credits, depending on various factors, including the date the funds were obtained.

1. The repayments of principal amount and interest are permitted for loans/credits obtained after June 20, 2023, in particular, if:

• the annual interest rate does not exceed 12%;
• the principal is repaid using the borrower’s own foreign currency (not purchased or borrowed from a resident): fully, for loans/credits with a term of less than one year; during the first year, for loans/credits with a term of more than one year. 

2. The interest payments on loans/credits obtained prior to June 20, 2023, are allowed, provided that: 

• the interest payment date is due after February 24, 2022 (inclusive);
• the borrower had no overdue debt as of February 24, 2022;
• under a single agreement, the borrower transfers no more than the equivalent of EUR 1 million per calendar quarter for overdue interest as of May 1, 2024 (this limit does not apply to interest payments due after April 30, 2024);
• funds for interest payments are not borrowed from other residents. 

3. Repayment of principal, interest, and other related payments is permitted if the loan/credit is granted partially or fully with the involvement of a microfinance institution, a foreign export credit agency/foreign state via a representative /foreign entity where the foreign state or foreign bank is a shareholder. 

All the abovementioned repayments may only be made after the due date specified in the loan/credit agreement.

Payments for Imported Goods, Services, and Works

For operating companies, the ability to freely pay for imported goods, services, and works is crucial for maintaining stable operations and fulfilling contractual obligations. 

Previously, cross-border payments for imports were restricted to a list of “critical” goods and services. These restrictions have now been lifted. 

Transfers abroad for the payment of received goods, services, or works (including fines, penalties, bonuses, and reimbursements under a foreign economic contract) may now be made without restrictions, provided that the goods, services, or works were or are being imported after February 23, 2021.

Payments Under the Investment Limit and Contributions to the NBU Special Account

As part of ongoing currency liberalization, the NBU has recently expanded the list of cross-border transactions permitted for certain categories of legal entities. 

Within the “investment limit” (the total amount of foreign currency transferred by foreign investors into the charter capital of a Ukrainian company starting from May 12, 2025), resident companies may: 

• settle payments for goods, services, or works imported before February 23, 2021;
• repay obligations under loans/credits obtained before June 20, 2023;
• refund advance payments to non-residents received before February 23, 2022;
• cover expenses for maintaining branches, representative offices, or other subdivisions abroad;
• pay dividends to foreign investors/non-residents for corporate rights/shares. 

The same list of transactions may be carried out by resident legal entities that have contributed to the NBU’s special account for raising funds to support the Armed Forces of Ukraine, with the total transaction volume limited to the amount transferred to that account starting from August 7, 2025.

Special NBU Permits for Cross-Border Transfers

Despite the strict conditions of the current framework, it still retains some flexibility for exceptional operations. 

An individual NBU permit may be obtained to carry out a transaction that does not meet the above conditions or is otherwise prohibited. To secure such a permit, the applicant must demonstrate, among other things, the importance of the transaction to state interests during martial law.

Conclusion

The NBU continues to gradually liberalize the framework for cross-border transfers from Ukraine, expanding the range of permitted transactions and easing restrictions introduced at the start of martial law. This reflects the broader goal of facilitating international settlements, attracting foreign investment, and maintaining Ukraine’s integration into global financial markets. 

However, most transactions remain subject to detailed conditions that businesses must carefully review and comply with when planning cross-border transfers.