The end of currency control as we knew it

For most of its independent history Ukraine operated a currency control regime in which anything not expressly permitted was prohibited. The 2019 currency law inverted that presumption, and the practical difference is very large.

What the old regime meant for a company

Individual licences for ordinary transactions. Mandatory sale of a share of export proceeds. Short deadlines for settling export and import contracts, with penalties for exceeding them. Restrictions on paying dividends abroad, on lending between related companies and on holding foreign accounts.

The cumulative effect was that a company trading in several currencies spent real management time on permissions rather than on trade.

What the law changed

The presumption: anything not prohibited is allowed. The licence requirement was replaced by a system of measures the central bank can apply when conditions require, and remove when they do not.

Settlement deadlines were extended, mandatory sale was abolished in normal conditions, and dividend repatriation became routine.

What wartime reintroduced

Restrictions, necessarily: limits on capital movement out of the country, controls on non-critical imports, and a fixed then managed exchange rate.

The important point is that these were applied as temporary measures within the framework rather than as a return to the old regime, and they have been eased progressively as conditions allowed.

What a treasury function should do

Watch the central bank's resolutions rather than the law, because the law sets the frame and the resolutions set what is actually permitted this month.

Under the old regime we prepared a separate justification file for every outward payment; under the new framework most transactions clear at the bank in a single step. That difference turned the treasury function from a defensive activity into a planning one. The restrictions the war brought back are temporary — what is permanent is that there is now a framework to return to.