On 5 November 2014, Regulation No. 699 of the National Bank of Ukraine on Application of Certain Hard Currency Laws in Free Economic Zone “Crimea” during Temporary Occupation came into effect.

The new regulation provides for the following:

  1. Individuals and legal entities registered or having permanent residence in free economic zone “Crimea” are considered to be non-residents (“Crimean  subjects”).
  2. Agreements entered into by Crimean subjects with other Ukrainian territories are considered to be used in lieu of foreign  economic  contracts.
  3. Cash transfers from inland Ukraine to Crimea and vice versa must comply with laws regarding transfers to and from abroad, taking into account the requirements of the new regulation. Ukrainian residents may make transfers to Crimean subjects to pay obligations related to property in Crimea (other than securities) acquired by such residents before the enactment of the Ukrainian Law on Creation of Free Economic Zone “Crimea” and Peculiarities of Business Activity in Temporarily Occupied Ukrainian Territory” (the “Crimea Law”), i.e., before 27 September 2014.
  4. Transactions in Crimean subjects’ bank accounts opened before 27 September 2014 must be terminated and such accounts must be closed.
  5. The Law of Ukraine on Payment Systems and Money Transfers in Ukraine apply to Crimea, however:
  • electronic payment instruments issued in Crimea, including mobile payment instruments, may not be used in the rest of Ukraine to initiate any money transfers;
  • electronic payment instruments issued by the internal state payment system or international payment systems may be used in Crimea.
  1. The regulation bans:
  • any investments by residents in investment facilities located (registered) in Crimea;
  • any transactions on mainland Ukraine in Russian rubles under any new bank deposit agreements and credit facility agreements and such agreements executed before 27 September 2014;
  • carrying Russian rubles in cash through Crimean border, other than by individuals not in excess of the equivalent of 10,000 Hryvnia (approximately US$800).