By a new Resolution of the National Bank of Ukraine (the "NBU") No. 654 dated 1 October 2015 (the "Resolution") a procedure on application of sanctions was introduced.

The Resolution was adopted in accordance with the Decree of the President of Ukraine "On application of special sanctions" (the "Decree"), which introduced a number of special measures against nearly 90 legal entities and 400 individuals, mostly from Russia.

According to the text of the Resolution, depending on the sanction specified in the Decree for the person concerned, banks shall:

  • Refuse to establish business contacts with such person
  • Suspend financial transactions and/or their execution
  • Suspend execution of financial liabilities
  • Take measures to prevent the removal of capital from Ukraine
  • Block funds and stop financial transactions
  • Decline to proceed with t other banking transactions