Banking

Can a foreign-owned company open a bank account in Ukraine?

Published 13 August 2026 · facts checked against the primary sources on 2026-08-08 · Ukraine For ALL, Kyiv

The National Bank's document list is short. What takes weeks is the bank's due diligence: who ultimately owns the company, where the money comes from, what the account is for.

What does the National Bank's instruction actually require?

Very little on paper. For a resident company, the NBU Instruction on opening and closing accounts (approved by NBU Board Resolution No. 162 of 29 July 2022) asks for the list of persons authorised to operate the account and sign payment instructions, an application, and a written account agreement. Whoever opens the account presents a passport and proof of authority (para. 31, Section II).

Two rules sit above that list. Under para. 9, Section I, an account is opened only after customer due diligence under the Law of Ukraine "On Prevention and Counteraction to Legalisation (Laundering) of the Proceeds of Crime…" No. 361-IX. Under para. 21, Section I, documents issued by foreign authorities must be legalised unless a law of Ukraine or an international treaty provides otherwise, and copies must be notarised.

A non-resident legal entity opening an account in its own name faces more: an apostilled or legalised extract from the trade, banking or court register of its home country and an apostilled or legalised power of attorney (para. 34, Section II), plus a copy of the document confirming registration with the Ukrainian tax authority (para. 25, Section I).

What does the bank ask about the owners?

The bank must establish the ultimate beneficial owner (UBO) and understand the ownership chain — not just read a register. Annex 4 to the NBU Regulation on financial monitoring by banks (Resolution No. 65 of 19 May 2020) governs this:

The ownership structure is also a filing obligation towards the state registrar, described in how does a foreigner register a company in Ukraine. Ministry of Finance Order No. 163 of 19 March 2021 sets its form: a schematic showing every person who directly or indirectly owns the entity, each participation share, and every person able to exert significant influence regardless of formal ownership. Where foreign companies, foreign individuals or trusts appear in the chain, official supporting documents must be attached — unless data on those persons is already in the Unified State Register (para. 4).

Changes matter too. Under the Law on State Registration of Legal Entities No. 755-IV, a change of UBO must be registered within 30 business days. Failure to file UBO data carries a fine on the company itself of UAH 17,000 to UAH 340,000 (1,000–20,000 tax-free minimum incomes at UAH 17 each), imposed by the Ministry of Justice (Art. 35(4)).

When can the account start making payments?

Money can arrive before money can leave. Under the Tax Code of Ukraine, the bank notifies the tax authority on the day the account opens (Art. 69.2), the tax authority sends a notice of registration or refusal no later than the next business day (Art. 69.3), and debit operations may begin only from the date the bank receives that notice, or the date of registration by tacit consent (Art. 69.4).

So the tax step is measured in days. Due diligence is measured in weeks.

What can the account do under wartime currency rules?

Less than a peacetime account. NBU Board Resolution No. 18 of 24 February 2022 sets the baseline in paragraph 14: cross-border transfers of currency values from Ukraine are prohibited, except in a long list of enumerated cases. Every outgoing payment must fit an exception.

• Imports of goods — permitted where delivery took place after 23 February 2021 (para. 14(2)).
• Dividends to a foreign investor — permitted since 13 May 2024 (para. 14(46)), subject to all of: dividends accrued for a period starting from 1 January 2023 (not out of earlier retained earnings or reserve capital); a cap of EUR 1,000,000 per calendar month, processed through the NBU's automated "E-limits" system; the issuer registered for at least 12 months; and the investor holding the corporate rights for at least 6 months. Subparagraphs 46-1, 46-2 and 46-3 add separate dividend routes built around guaranteed foreign debt securities, and the Resolution states expressly that subparagraph 46's conditions do not apply to them.
• Capital injected since 12 May 2025 — subparagraph 14(57) lets a resident make currency payments up to the total that foreign investors have transferred from abroad into its share capital since 12 May 2025. Paying dividends to the foreign investor or non-resident is one of the listed purposes; others include imports delivered on or before 23 February 2021 and servicing loans received before 20 June 2023. Everything runs through one bank of the company's choice, and that bank must hold documents evidencing the inbound investment.
• The "loan limit" — in force since 14 January 2026 (NBU Board Resolution No. 2 of 13 January 2026, adding subparagraph 14(41-1)). The cap equals loan proceeds received in foreign currency from abroad, minus principal already repaid abroad under the same loan. It may be spent only on the purposes listed in the second paragraph of subparagraph 57. The conditions are cumulative: every provision, receipt and repayment of any part of the loan must occur after 1 January 2026; no international financial institution may be lender, guarantor or surety; the money must arrive from abroad into the borrower's current account in a Ukrainian bank; and all operations must run through the single servicing bank.

One number governs the cost side of any such loan. Payments to the lender — interest, fees, charges and other amounts combined — may not exceed what the loan would cost at 12% per annum, and the bank recalculates that cap at every payment (paras. 19-6, 19-7). Transfer commissions of the servicing bank and the non-resident bank are excluded from the count. A contract rate above 12% is not prohibited; the excess simply cannot leave Ukraine. Payments also cannot be made ahead of the contractual due date (para. 19-5).

One restriction is ownership-based rather than transaction-based. Paragraph 15 of Resolution No. 18 suspends debit operations on accounts of legal entities whose ultimate beneficial owners are residents of Russia or Belarus, with narrow carve-outs for salaries, taxes, utilities and payments to the state.

Why do banks refuse?

Refusal is often not discretionary. Article 15(1) of Law No. 361-IX requires a bank to refuse or terminate business relations where identification, verification or establishing the UBO is impossible; where the client is assigned an unacceptably high risk or does not supply the documents needed for due diligence; where the information submitted is inaccurate or misleading; or where the beneficiary of a transaction cannot be identified.

Annex 19 to NBU Regulation No. 65 lists the criteria that push a young company towards "shell company" classification: a mass-registration address, owners registered in a jurisdiction on the Cabinet of Ministers' offshore list or one with nominee or trust ownership mechanisms, no premises, assets or staff proportionate to the declared activity, and entities that claim different UBOs, directors and addresses yet pay from the same IP address. The geographic criteria cover the Cabinet's offshore list, FATF black- and grey-listed jurisdictions, countries the European Commission identifies as having weak AML/CFT regimes, and countries carrying elevated corruption or terrorist-financing risk.

Where people get stuck

1. The structure chart above the company. An intermediate holding company above the Ukrainian entity is legal, but the bank must trace ownership to a natural person — and it may not simply copy the Unified State Register (Annex 4, para. 4). Nominee shareholders and trusts turn a two-week onboarding into a two-month one.
2. A mismatch with the state register. The bank checks the ownership structure against the register within five business days and records discrepancies. If the register was never updated after a share transfer, the client fixes the register before onboarding continues.
3. Documents that were never legalised. Corporate papers from abroad need an apostille or consular legalisation unless a treaty says otherwise, plus notarised copies. Scans and plain secretary's certificates get rejected.
4. Assuming the account can pay anyone. It cannot. Paragraph 14 of Resolution No. 18 bans cross-border transfers except in listed cases; a payment that fits no exception will not go out, however reasonable it looks commercially.
5. Russian or Belarusian beneficial owners anywhere in the chain. Under paragraph 15 of Resolution No. 18, that alone freezes outgoing payments.

FAQ

Does a foreign shareholder have to be in Ukraine to open the account? Not necessarily. The person opening it must present identification and proof of authority, and a power of attorney issued abroad must be apostilled or legalised. Remote establishment of business relations is permitted where the NBU's financial monitoring requirements are met (Instruction No. 162, para. 18, Section I).

How long does it take? The regulated part is short: the tax authority must respond to the bank's notice no later than the next business day (Tax Code, Art. 69.3). The unregulated part is due diligence, and no statute sets a maximum for it.

Can profits be sent to the foreign parent? There is more than one route. Subparagraph 14(46) of Resolution No. 18 is the general one: periods from 1 January 2023, EUR 1 million per month through E-limits, plus the 12-month and 6-month conditions. Subparagraph 14(57) opens a second, sized by the capital foreign investors injected from abroad into the company's share capital since 12 May 2025, with dividends among its permitted uses. The loan limit under subparagraph 14(41-1) can also be spent on those same purposes. Note that the Resolution expressly disapplies subparagraph 46's conditions to subparagraphs 46-1 to 46-3, and says nothing of the kind about subparagraph 57 — a point to settle with the servicing bank before relying on it.

Does a refusal by one bank block the others? Not automatically. But Article 15(2) of Law No. 361-IX lets financial institutions exchange information about persons refused an account.