The largest easing of currency restrictions since the start of the full-scale invasion

Legal Alert

The National Bank of Ukraine (“NBU”) continues to ease currency restrictions imposed at the beginning of the full-scale war. This time, the regulator has introduced the largest easing of currency restrictions for business, in particular those related to payment for imported works and services, payment of dividends to non-residents, repayment of loans from non-residents, and other easing measures.

The respective changes were introduced by the NBU’s Resolution No. 56 dated 3 May 2024, which amended the NBU’s Resolution No. 18 dated 24 February 2022.

Although the said Decree No. 56 came into force on 4 May, the repatriation of dividends accrued for the period from 1 January 2024 will be allowed from 13 May. Below is a detailed overview of the main currency easing measures:

  • All currency restrictions on payments for the import of works and services rendered after 23 February 2021 have been lifted. The CMU’s Resolution No. 153 is expected to be canceled.
  • Businesses are now allowed to repatriate dividends accrued based on the results of activities for the period from 1 January 2024. The monthly limit for the repatriation of dividends amounts to the equivalent of EUR 1 million. Compliance with the rule will be monitored through the NBU’s automated information system E-Limits.
  • It is now possible to transfer funds abroad under the leasing/rental agreements. Previously, this permission was limited to vehicle leasing/rental only.
  • Representative offices of international card payment systems and foreign airlines are allowed to purchase and transfer foreign currency for the benefit of parent companies. The monthly limit for such transactions amounts to the equivalent of EUR 5 million.
  • Restrictions on repayment of “new” foreign loans (received from abroad after 20 June 2023) have been eased:
    • The prohibition on purchasing foreign currency to repay “new” cross-border loans now only applies to loans with a term of up to one year.
    • Purchasing foreign currency to pay interest on all “new” loans is allowed regardless of the term of the loan.
  • The NBU now allows payment of interest on “old” cross-border loans (received before 20 June 2023) provided that the following requirements are met simultaneously:
    • Under the loan agreement, interest is payable for the period from 24 February 2022.
    • No overdue debt as of 24 February 2022 under the loan agreement.
    • Under a single agreement, no more than the equivalent of EUR 1 million per one calendar quarter may be transferred for interest payments overdue as of 1 May 2024. This restriction will not apply to future scheduled interest payments.
    • Purchasing and transferring funds from loans or credits (including repayable financial aid) received from residents is prohibited.
    • No provision for early payment or restructuring of overdue payments.

We believe that the introduced currency easing measures will help support the Ukrainian businesses and attract foreign capital.

We will continue to monitor changes in currency legislation during martial law and will share useful information with you.

The Deloitte overview indicated above is solely informative by nature and should not be treated as an official advice without a separate engagement of our professionals.

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