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How Ukraine’s Banking System and FX Market Will Work from 24 February 2022 Under Martial Law Throughout Ukraine

How Ukraine’s Banking System and FX Market Will Work from 24 February 2022 Under Martial Law Throughout Ukraine

The National Bank of Ukraine has passed a Resolution outlining how Ukrainian banks will operate now that martial law has been imposed throughout the country. Martial law is a special regime under which:

  • Banks ensure the uninterrupted operation of their branches unless doing so puts at risk the lives and health of the public.
  • Banks continue to operate subject to the restrictions stipulated by this Resolution.
  • Banks provide uninterrupted access to safe deposit boxes.
  • It is ensured that all cashless payments go through without limitation.
  • ATM cash replenishment is carried out without restrictions.
  • The NBU provides unlimited cash support.
  • The NBU grants unlimited unsecured refinancing loans to banks, with up to one-year maturity and an option to extend the loan by another year, so that banks can maintain their liquidity.
  • Payments to and by the Ukrainian government are made without restrictions, in accordance with legislation governing this special period.

The Resolution also imposes temporary restrictions, effective 24 February 2022. Those include measures that:

  • suspend the operation of Ukraine’s FX market, except for FX sales by customers
  • fix the official exchange rate for 24 February 2022
  • limit cash withdrawals from client accounts to UAH 100,000 per day (excluding salaries and social benefits), except for businesses and institutions that ensure the implementation of the government’s mobilization plans (objectives) and entities that have the NBU’s special permission to operate without paying commissions
  • prohibit the release of cash from client accounts in foreign currency, except for businesses and institutions that ensure the implementation of the government’s mobilization plans (objectives) and entities that have the NBU’s special permission
  • introduce a moratorium on cross-border foreign currency payments (except for businesses and institutions that ensure the implementation of the government’s mobilization plans (objectives) and entities that have the NBU’s special permission)
  • suspend debit transactions from the accounts of residents of the state that has carried out armed aggression against Ukraine
  • suspend the issuing of electronic money, the replenishment of electronic wallets with electronic money, and the distribution of electronic money by issuing banks.

These measures aim to ensure the reliable and stable operation of Ukraine’s financial system and facilitate the fullest support for activity of the Armed Forces of Ukraine, as well as the smooth operation of critical infrastructure.

We emphasize that the NBU Board continues to operate in accordance with the Law of Ukraine On the National Bank of Ukraine, and Rules of the NBU Board Operation During Special Period approved by NBU Board Decision No. 606 dated 21 August 2019, regulatory and other documents of the NBU.

The changes outlined above were approved by NBU Resolution No. 18 On the Operation of the Banking System Under Martial Law dated 24 February 2022.

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