NBU Resolution No. 90 has been in effect since August 11, 2026. The press called it the largest package of currency easing since the start of the war. A month later, investors summed it up: buying foreign currency got easier, transferring it to a foreign brokerage account remained just as hard as before. And the main barrier isn’t in Ukraine at all. It sits in the compliance departments of European banks and payment services.
The topic was covered in detail by Oleksii Rud, founder of Xpaid, in a conversation with the UkrInvestClub channel: limits, documents, common mistakes, and cases from consulting Ukrainians on European financial compliance. The full episode is below, followed by the key takeaways in the text.
Brief: what changed and what didn’t
Question |
Before August 11, 2026 |
Under Resolution No. 90 |
|---|---|---|
Non-cash currency purchase |
UAH 50,000 per month |
UAH 200,000 per month |
Foreign securities in Ukraine |
Purchase closed since 2022 |
Allowed within the same UAH 200,000, via licensed Ukrainian custodians |
Bank metals |
Separate restrictions |
Within the UAH 200,000 limit |
Cash currency withdrawal |
Equivalent of UAH 100,000 per day |
Limit raised |
SWIFT transfer from an individual to their own brokerage account abroad |
Prohibited |
Prohibited. Only payments for goods, works, and services are allowed |
Card-to-card abroad |
Not offered by all banks, fees up to 2–4% |
Unchanged |
A detailed breakdown of the resolution itself is available in a separate article (Ukrainian only): UAH 200,000 Non-Cash Currency Limit: What the NBU Changed in August 2026. Here we focus on what happens after the currency has been purchased.
Why Direct Funding of Interactive Brokers or Freedom Finance Still Doesn’t Work
The resolution mentions the possibility of transferring funds from a currency account to a recipient’s account abroad. Many read this as permission to fund a broker via SWIFT payment. It isn’t. The provision covers payment for goods, works, and services. Investment transfers by individuals to their own accounts abroad remain closed.
What this means in practice:
- A Ukrainian with a foreign bank or payment account can buy more currency in Ukraine, but to get it to a broker, they first need to fund that foreign account.
- The foreign account still needs to be opened. Over 40 payment institutions worldwide work with Ukrainians, and choosing between them is left to the individual, often based on chat-group rumors.
- Payment services convert hryvnia at their own cross-rate, which the client has no control over.
- Once funded, that institution’s own compliance kicks in. It doesn’t depend on NBU decisions.
In other words, the limit quadrupled, but the route to a broker remained a three-step process: buy currency, move it to a foreign account, pass verification.
Why the NBU Chose This Particular Format
The regulator allowed currency purchases but not mass currency withdrawal. Money stays within the banking system; only the currency on screen changes. Reasons given in the episode:
- Gold and currency reserves exceed $50 billion, with a target of $70 billion by the end of 2026. There’s a resource base to support the exchange rate.
- Liberalization is written into the IMF program and is proceeding on schedule. This is fulfilling obligations, not a willingness to release capital.
- The format was chosen to avoid triggering large-scale capital flight.
For investors, the takeaway is simple: pressure on the hryvnia hasn’t gone anywhere, and currency diversification is still needed. The only question is how to get there without getting blocked.
At What Amount Does a European Bank Start Asking Questions
Up to a certain threshold, a Ukrainian with a Wise, Revolut, or European bank account won’t notice any procedures. Problems start once amounts exceed typical limits. Practical benchmarks from the episode:
Annual transfer amount |
What usually happens |
|---|---|
Up to €1,000–1,500 |
No extra questions |
Up to €10,000 (the threshold used to be €15,000; EU regulation has tightened) |
Payment services usually ask nothing |
€10,000–€20,000 |
The chance of a source-of-funds request rises noticeably |
€50,000 or more |
A request is almost guaranteed. You’ll get a letter asking “where did this money come from” |
Some services have their own triggers. Genome, for example, automatically blocks further transfers once 70% of the limit is used and asks the client to fill out a source-of-funds questionnaire. Wise and Revolut mass-blocked Ukrainian accounts in 2024–2026, often demanding proof of a European residential address after transactions had already gone through.
An important nuance: many payment institutions only work with EU residents at all. A Ukrainian can complete registration, then a few months later receive a request for a European address they don’t have.
Take this short quiz and find out how prepared you are.
- 1 minute
Source of Funds and Source of Wealth: What’s the Difference
European compliance asks two different questions.
Source of funds (SoF) answers where the money for a specific transaction came from. Sold an apartment, received dividends, withdrew from a deposit.
Source of wealth (SoW) answers how you accumulated your capital in the first place. Here the whole financial history is examined.
A document that satisfies SoF often doesn’t satisfy SoW. A classic example from the episode: a client shows a ten-year-old apartment sale agreement. As a transaction source, it may still pass. But the bank doesn’t see that this same money sat untouched for ten years, and can’t trace its path. Later, when another institution or the tax authority wants to review the case, such a document raises questions.
Which Documents Are Accepted, and Which Cause Problems
Document |
How EU compliance treats it |
|---|---|
Annual tax return |
Ideal |
Sole proprietor (FOP) statement with declared income |
Ideal |
Confirmation of dividends received |
Ideal |
Property sale agreement, no older than 3 years |
Good |
Property sale agreement, older than 3 years |
Red flag |
Inheritance, loan agreements |
Possible, but requires in-depth review |
Account statement showing “money sat in a deposit” |
Weak: the same statement shows parallel spending, and the sum can’t be tied to the transaction |
Salary statement with no clear accumulated amount |
Weak |
The rule bankers repeat: a document must clearly show how much you earned and that this specific money is what’s going into the transfer. For more on preparing the document package, see How to Confirm the Origin of Funds. EN not found — Ukrainian original: Common Client Mistakes with SoF Documents.
What Not to Send the Bank
The second common mistake is the opposite of the first. The client gets a request and sends everything they have: five years of statements, every agreement, employment certificates. Every extra document gives the compliance officer a new reason to ask questions. Send only what answers the specific question, and nothing more.
Tax Residency: The Second Trap After Compliance
Some Ukrainians acquired tax residency in another country over the years of war, or now live between two jurisdictions. When you provide a European address on a payment service’s form, information about your transactions gets reported to that country’s tax authority under automatic exchange rules (CRS). If it doesn’t match what you declared, questions follow.
Dmytro Karpilovskyi (host of the UkrInvestClub channel) gave his own example: living in Ukraine with a sole proprietorship and his center of vital interests here, he still has an ongoing dispute with the German tax authority, because he lived in Germany from 2001 to 2017. Dual residency can drag on for years. Before large transfers, it’s worth figuring out where you’re a resident and what follows from that. More on the topic: Double Taxation: What It Is and How to Legally Avoid It.
Who Seeks Consultations and With What Problems
Oleksii Rud shared inquiry statistics from recent years:
- Previously, most clients were transferring money to buy housing in Europe. Now that’s about half or a bit less.
- The other half: active investors funding brokerage accounts, joining venture syndicates, or buying stakes in European companies. Their need is recurring, often monthly.
- 70–80% of people come for a consultation before doing anything. They see information on YouTube and want to understand the rules of the game.
- 20–30% arrive already with a problem.
Typical situations from the second group:
- Wanted to bring cash into Europe, but banks don’t accept cash, or ran into problems declaring it at the border.
- Used an unreliable service, and the bank started asking questions.
- Deposited money into an account with no issues, but questions arose on withdrawal.
- Got a letter from Revolut or Wise: “withdraw your funds, we’re closing the account.” The money is there, but they don’t know where to safely move it.
How Much a Mistake Costs
The classic scenario after a block: the client hires a lawyer in Europe. Rates start at €200–250 per hour, and correspondence with the bank takes 6–10 hours. That’s €1,500 to €2,500, with no guarantee of a result.
Worse case: the bank passes information to tax or law enforcement authorities. If the origin of funds can’t be proven, the person risks an additional 20–23% tax payment or an administrative case that stays on their financial record.
Cases from Practice
€500,000 from father to son in Germany. The father wanted to transfer money to his son’s German account. Under German law, this amount between father and son doesn’t require a gift agreement. But the bank can request documents regardless of the law. The case was closed after both parties prepared proof of the funds’ origin and opened accounts suited to such a transaction.
A client in Norway, then Albania. Norway, Sweden, Switzerland, and Austria have some of the strictest compliance regimes in Europe. The client passed a Norwegian bank’s review, then later transferred the same money to Albania for relocation. Two different compliance regimes, EU and non-EU, with one document package.
Transfers up to €10 million. At this scale, bank questions are inevitable. The only difference is whether the client is ready to answer them before the money gets stuck.
Which Transfer Methods Are Toxic Right Now
The episode separately covered practices to stay away from.
Method |
Why it’s risky |
|---|---|
Loans from companies or individuals as “legalization” |
Used to work, now banks block it almost every time |
Moving cash physically (handed over in Kyiv, picked up in Spain) |
Capital moves, but the bank isn’t part of it. Legalizing cash abroad is harder than in Ukraine |
Splitting amounts (smurfing) into €10,000 chunks or from multiple cards into one account |
Deliberate splitting to bypass controls qualifies as a criminal offense. Plus, origin becomes impossible to prove |
Street exchangers in Europe that credit euros to your bank account |
The exchanger is itself subject to compliance. Its review comes later, and you get the bank’s questions |
Consultants and realtors earning referral fees from such exchangers |
Their interest is the commission, not your safety |
What Legal Tools Work, But Have Limits
- SWIFT. Transparent and straightforward, but NBU limits don’t allow investment transfers through it.
- International payment services (Wise and others). A workable method with a catch: at any point they may request proof of a European address or close the account of a non-EU resident.
- Cash across the border with declaration. Works if you’re prepared with the right document package, and prepared for the fact that the decision at the border rests with a specific border officer.
- Digital assets (stablecoins). There are licensed companies on the market that document every conversion transaction. The key condition: a license in the relevant registry, and documents that will still answer “where did the money come from” years later. Checking a provider’s status is on you.
Perception has shifted in recent years: banks have become a storage tool, payment institutions a transit tool. Compliance operates under European rules in both cases.
Pre-Compliance: Preparing Before the Bank Asks Questions
Bank compliance happens after the transfer. Pre-compliance happens before it. It means reviewing your own case against the same criteria the institution will use.
What such preparation includes:
- Document inventory. What proof of the funds’ origin you have, and whether it’s older than three years.
- Residency. Where you’re a tax resident, and which addresses appear on your forms.
- Transfer history. How much you’ve already transferred this year through each service, and how close you are to their limits.
- Purpose of the transfer. A brokerage account, real estate, a company stake. Each purpose comes with a different expected document package.
- Chain logic. Every link from the Ukrainian account to the final recipient needs to be clear and documented.
If, after such a review, you transfer €50,000 to a payment account, either no request will come, or you’ll answer it with a ready package. The institution always makes the final call, but a prepared client gets through review faster and without a €250-an-hour lawyer.
Checklist Before Your First Large Transfer
- Annual tax return or FOP statement from recent years on hand.
- Property sale documents no older than 3 years.
- Clarity on where you’re a tax resident and what follows from that.
- Knowledge of which countries your chosen payment service works with, and whether it requires a European address.
- Your annual transfer total calculated, with the €10,000 threshold in mind.
- No splitting of amounts and no third-party “help” via loans.
- Understanding of which documents to send in response to a request, and which not to.
Conclusions
NBU Resolution No. 90 provided more currency, but no direct road to foreign assets. Workarounds exist, and that’s exactly where the scrutiny begins. From €10,000 a year, almost every Ukrainian runs into a question about the origin of funds; from €50,000, that question is guaranteed.
Transactional complexity isn’t a reason to give up on diversification. Legal routes exist, and they can be completed without stress if the documents are ready before the bank asks for them. Time spent on pre-compliance costs less than months of correspondence with a blocked account.
Frequently Asked Questions
Can I transfer money directly from a Ukrainian bank to Interactive Brokers after Resolution No. 90?
No. The SWIFT transfer allowance covers payment for goods, works, and services. Funding your own brokerage account abroad remains closed for individuals. You can fund a broker from a foreign account. A step-by-step guide is available in How to Fund Interactive Brokers from Ukraine in 2026.
At what amount does a European bank require proof of the origin of funds?
What happens if I can't confirm the origin of funds?
Will a ten-year-old apartment sale agreement work as proof?
Why did Wise or Revolut block my account even though I didn't break any rules?
Is it legal to split a transfer into several smaller amounts?
This material is for educational purposes only and does not constitute personal financial, investment, or legal advice. Any decisions are yours to make.
XPAID provides consulting, informational-advisory services, and software (technical) solutions. XPAID is not a Crypto-Asset Service Provider (CASP), does not provide payment, investment, or other financial services, and does not participate in clients’ financial transactions.
