KPMG Ukraine Guide Helps Foreign Investors Navigate Wartime Banking System

The Misconception Worth Correcting First

"It's not uncommon for investors to assume that banking in Ukraine is opaque, unstable, or disconnected from international standards," says Oleg Goshchansky, head of the KPMG Ukraine Gateway initiative. "These perceptions are often shaped more by past crises and recent wartime headlines than by the current reality."

That framing matters as a starting point for anyone building operations in Ukraine. The country's banking sector was fundamentally reshaped after the 2014 EuroMaidan Revolution. Under the National Bank of Ukraine's tightened oversight, banks are well capitalized and regulatory alignment with EU standards now sits at roughly 80%. The sector turned a profit of 24.7 billion hryvnia ($609 million) in 2022 despite the full-scale invasion, and surged to 83.2 billion hryvnia ($2 billion) in 2023 as wartime monetary policy took hold. That is not the picture of systemic collapse that many deal teams expect before their first Ukraine engagement. As Goshchansky puts it, "for informed investors, the challenge is less about banking risk and more about distinguishing between legacy narratives and current institutional realities."

The Actual Landscape: Who the Banks Are

Ukraine's banking infrastructure is more connected globally than most outsiders realize. All authorized Ukrainian commercial banks are members of SWIFT, which means international wire transfers remain operational. PrivatBank, nationalized in 2016 and now the country's largest bank by assets with approximately 1,200 branches and over 7,000 ATMs, anchors the retail and SME side. Oschadbank, the state savings bank, serves more than 30 million Ukrainians. On the international side, EBRD-backed trade finance partners operating in the country include Credit Agricole Ukraine, OTP Bank, Raiffeisen Bank Aval, and the State Export-Import Bank of Ukraine, all of which offer established channels for cross-border transactions.

For foreign firms evaluating where to bank, the practical consideration is less about systemic risk and more about choosing an institution with experience handling non-resident corporate structures. The Fourth Rapid Damage and Needs Assessment, published in February 2025, pegged Ukraine's reconstruction and recovery costs at 506 billion euros over the coming decade, a figure that has made institutional relationships with internationally oriented banks increasingly important for deal teams entering the market.

Opening Accounts: Personal vs. Corporate

The friction point for most foreign operations is corporate account setup, not personal banking. For individuals, opening a personal account in Ukraine is straightforward: a branch visit with a passport (plus a W9 form for U.S. citizens) is generally sufficient. The process can take under an hour at most major banks.

Corporate account opening is a different matter and takes between one day and one week depending on the bank's internal procedures. Required documentation typically includes:

Foreign entities or shareholders with complex ownership structures, or those with any exposure to high-risk jurisdictions, should expect extended review timelines. Engaging a local legal advisor before submitting documents substantially reduces back-and-forth delays.

KYC in Wartime: Stricter, for Specific Reasons

Olena Markarenko, partner in risk consulting and ESG at KPMG Ukraine, describes how the KYC environment has evolved since February 2022. "Beyond the standard areas such as ownership, sanctions, high-risk jurisdictions (including offshore regions), and violations of anti-corruption or anti-monopoly legislation, we also (have to) deeply analyze business connections, especially in the context of the ongoing war," Markarenko noted. The enhanced scrutiny extends specifically to a company's operational network: counterparties, supply chains, and any business relationships that could carry wartime reputational or compliance risk.

This level of diligence is not arbitrary bureaucratic friction. It reflects Ukraine's broader mandate to maintain banking vigilance during an active conflict, with institutions managing operational and reputational risk simultaneously. For incoming investors, the practical implication is preparation: assembling a clean, complete compliance package upfront, with clear beneficial ownership documentation and a documented source-of-funds narrative, will compress the onboarding timeline significantly.

Currency Controls: The Real Constraint

The National Bank of Ukraine operates under Resolution No. 18, "On the Operation of the Banking System Under Martial Law," which has governed currency circulation since the full-scale invasion began in February 2022. This is the single most operationally significant constraint for foreign employers and deal teams moving money in and out of Ukraine.

Current restrictions include limited access to certain currency circulation instruments and limitations on operational cross-border payments. Critically for investors, dividend repatriation to non-residents was re-permitted beginning May 13, 2024, a significant easing after two years of lockdown. July 2024 brought further relaxation: residents can now pay dividends to non-residents subject to a monthly limit of EUR 1 million for interest income on foreign-issued debt securities. August 2025 introduced an additional mechanism, allowing currency transactions above established limits when company funds are simultaneously transferred to a designated NBU account in support of the Armed Forces of Ukraine.

The direction of travel is clearly toward relaxation, but the pace remains cautious. Businesses should not assume that further easing will be automatic or rapid; the NBU has consistently signaled that it will move incrementally rather than unwind controls in large batches.

Paying Employees and Contractors

For HR and finance teams managing Ukrainian employees or contractors, the practical daily reality is more functional than the regulatory complexity suggests. The hryvnia-denominated payroll system operates normally. Ukrainian banks' mobile banking infrastructure, including PrivatBank's Privat24 app and Universal Bank's Monobank platform, is highly developed and broadly used for salary receipt and everyday transactions. Bank deposits carry a 100% government guarantee under martial law, which has supported confidence in the system even among Ukrainian workers during the conflict.

Foreign employers paying Ukrainian contractors in foreign currency should be aware that NBU rules govern how and when foreign currency can be converted and moved. Payments for import of services, intellectual property, and other non-property rights have seen restrictions eased, but transactions above certain thresholds still require documentation. The EUR 1 million quarterly cap on certain cross-border interest payments is a practical ceiling that deal teams financing local operations through intercompany loans will need to account for in their cash flow planning.

What Finance and HR Teams Should Have Ready

Before initiating banking relationships or payroll structures in Ukraine, the following checklist reduces friction:

• Full UBO documentation with certified ownership structure charts
• Source-of-funds narrative prepared in advance of KYC submission
• Confirmation that no counterparties appear on Ukrainian, EU, or U.S. sanctions lists
• A local legal or compliance advisor familiar with NBU Resolution No. 18
• Currency transaction planning that accounts for the current repatriation limits
• A designated in-country point of contact at the chosen bank's corporate team

Ukraine's total external financial assistance exceeded $52.4 billion in 2025, equivalent to roughly 24% of GDP, including $37.9 billion under the G7 Extraordinary Revenue Acceleration initiative. That volume of institutional financial flow through the Ukrainian banking system is itself a signal: the infrastructure is handling serious transaction loads. The challenge for incoming investors is less systemic than procedural, and most procedural obstacles are navigable with preparation.

The reconstruction window is attracting more attention from international teams, but those moving earliest will spend far less time in banking setup limbo if they treat KYC and currency planning as operational essentials rather than afterthoughts.