On 9 July 2024, the National Bank of Ukraine’s Resolution No. 84 revised settlement deadlines regarding certain export and import transactions. These amendments are primarily aimed at strengthening the resilience of Ukraine's national security and defence sector, as well as liberalising restrictions for agricultural exporters. 

The main revisions include: 

  • Settlement deadlines have been cancelled for military and dual-use goods, as well as equipment imported by executors of state contracts for defence procurement or for creating and/or expanding production facilities for manufacturing defence goods, and for executing such contracts with state customers. 

However, executors of state contracts must be included in the electronic register of tenderers and executors of state contracts in order to benefit from this amendment. 

  • Settlement deadlines have been extended from 90 to 120 calendar days for exports of specific agricultural products (wheat, rye, barley, oats, corn, etc.) that were carried out from 12 July 2024. 

Settlement deadlines for exports of certain agricultural goods carried out from 12 July 2024 are therefore currently 120 calendar days, whereas settlement deadlines for transactions carried out from 11 November 2023 to 11 July 2024 inclusive remain 90 calendar days. 

Please note that the settlement deadlines for export-import transactions for other types of goods are currently 180 calendar days (as provided for by Resolution No. 18). Moreover, in addition to the cancellation of settlement deadlines for goods in the national security and defence sector, Ukrainian legislation also provides for other exceptions to the application of settlement deadlines (e.g. export of certain services and works). 

Our services

KPMG Law in Ukraine has a team of relevant specialists with extensive experience in supporting clients on currency control issues and currency restrictions in Ukraine, including the following services:

  • advising on all aspects of currency supervision, as well as targeted advice through analysis regarding situational specifics

  • drafting and preparing necessary documents

  • participating in negotiations with servicing banks and counterparties 

  • structuring operational activity and transactions to take into consideration effective restrictions

  • representing clients in disputes on currency regulation issues with regulatory authorities.