Ukraine -- Regulatory Status Regulatory Overview

Executive Summary

• Crypto is legal in Ukraine, with a foundational law passed in 2022 establishing a basic legal framework for virtual assets, but the market remains largely unregulated in practice as of 2025–2026 Ukraine - United States Department of State
• The primary regulator designated for virtual assets is the National Securities and Stock Market Commission (NSSMC), but the full implementing legislation required for licensing and market operations has not yet been enacted Ukraine - United States Department of State
• The legal framework for virtual assets is defined by the Law of Ukraine "On Virtual Assets" dated February 17, 2022, which establishes definitions and basic principles but delegates detailed regulation to future legislation that has not yet been adopted Ukraine - United States Department of State
• No entities have been licensed to operate as virtual asset service providers as of 2025, because the licensing regime is not yet operational pending adoption of additional legislation Ukraine - United States Department of State
• The National Bank of Ukraine has noted that the hryvnia remains the only legal tender, and digital assets are not recognized as legal tender in the country Ukraine - United States Department of State

Regulatory Framework

• The Law of Ukraine "On Virtual Assets" No. 2074-IX was adopted on February 17, 2022, and is the primary legislative act defining the legal status of virtual assets in Ukraine Ukraine - United States Department of State
• The law establishes that virtual assets are intangible goods and defines two categories: secured virtual assets and unsecured virtual assets Ukraine - United States Department of State
• The National Securities and Stock Market Commission (NSSMC) is designated as the primary state regulator for the virtual asset market in Ukraine Ukraine - United States Department of State
• The National Bank of Ukraine also plays a regulatory role, particularly regarding virtual assets secured by fiat currencies and issues related to the financial system Ukraine - United States Department of State
• The Ministry of Digital Transformation is involved in policy development for the digital economy, including virtual assets Ukraine - United States Department of State
• The law for virtual assets entered into force, but the key provisions regarding market regulation and licensing require amendments to the Tax Code and Civil Code, which had not been adopted as of early 2025 Ukraine - United States Department of State
• The State Service for Financial Monitoring (SSFM) is the financial intelligence unit responsible for anti-money laundering oversight, as Ukraine became a full member of FATF (Financial Action Task Force) and participates in Moneyval assessments Ukraine - United States Department of State
• Ukraine has been an official FATF member, and the SSFM functions under the Ministry of Finance with authority over AML compliance for financial entities, including those dealing with virtual assets Ukraine - United States Department of State
• The Law of Ukraine "On Prevention and Counteraction of Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism, and Financing of Proliferation of Weapons of Mass Destruction" (AML Law No. 361-IX) covers virtual asset service providers in its scope Ukraine - United States Department of State
• The Ukrainian government has published a "Strategy on Virtual Assets Development in Ukraine" which outlines reforms and describes a roadmap for creating a full crypto ecosystem in the country Ukraine - United States Department of State
• Ukraine is designated for Temporary Protected Status (TPS) in the United States; however, this relates exclusively to US immigration policy for Ukrainian nationals and has no bearing on Ukraine's domestic cryptocurrency regulatory regime Federal Register :: Extension of the Designation of Ukraine for Temporary Protected Status
• The US Treasury's Office of Foreign Assets Control (OFAC) has issued Ukraine-/Russia-Related Sanctions Regulations; however, these sanctions target specific entities in the financial sector and do not constitute regulation of Ukraine's domestic crypto market Federal Register :: Ukraine-/Russia-Related Sanctions Regulations
• The Law of Ukraine "On the Legal Regime on the Temporarily Occupied Territory of Ukraine" establishes that Russian legislation and practices have no legal force on Ukrainian territory, which provides a framework for enforcing Ukrainian crypto regulation in occupied regions Law of Ukraine on the Legal Regime on the Temporarily Occupied Territory of Ukraine and Ukraine's Policy towards Russia's Occupation of Crimea | Embassy of Ukraine in the Republic of India

Licensing Requirements

• The Law of Ukraine "On Virtual Assets" establishes that virtual asset service providers must obtain a license or registration to operate legally in Ukraine Ukraine - United States Department of State
• Licensing authority is vested in the National Securities and Stock Market Commission (NSSMC), which is responsible for issuing licenses to virtual asset service providers Ukraine - United States Department of State
• The categories of activities requiring licensing include: storing or managing virtual assets, transferring virtual assets, and providing intermediary services related to virtual assets Ukraine - United States Department of State
• The licensing procedure requires submission of documents to the NSSMC, including legal entity registration information, business plan, and information about the beneficial owner Ukraine - United States Department of State
• The NSSMC must make a licensing decision within a specified timeframe, but the detailed licensing regulations are still being drafted and have not yet been finalized Ukraine - United States Department of State
• The licensing regime requires the licensee to have a registered legal entity in Ukraine, with no requirements for foreign ownership restrictions specified in the law Ukraine - United States Department of State
• Capital requirements for virtual asset service providers are specified in the draft regulations but have not yet been adopted into binding legislation Ukraine - United States Department of State
• As of 2025, zero entities have been licensed as virtual asset service providers in Ukraine, because the licensing mechanism is not yet fully operational pending adoption of amendments to the Tax Code and other legislation Ukraine - United States Department of State
• The Ukrainian Parliament (Verkhovna Rada) continues to work on draft laws that would activate the licensing regime, including Draft Law No. 10225-1 on amendments to the Tax Code regarding virtual assets, but these had not been passed as of 2025 Ukraine - United States Department of State
• There is no issuance of any license for virtual assets as of 2025, which means crypto businesses operate in a legal gray area where the law exists but is not yet fully enforceable Ukraine - United States Department of State

AML/KYC Requirements

• Ukraine is a full member of the Financial Action Task Force (FATF), meaning it has committed to implementing FATF standards including FATF Recommendation 15 on virtual assets and virtual asset service providers Ukraine - United States Department of State
• The Law of Ukraine "On Prevention and Counteraction of Legalization (Laundering) of Proceeds from Crime" defines virtual asset service providers as subjects of primary financial monitoring, making them subject to AML obligations Ukraine - United States Department of State
• Virtual asset service providers are required to conduct customer due diligence (CDD) by identifying and verifying their customers before establishing a business relationship or conducting a one-time transaction Ukraine - United States Department of State
• Enhanced due diligence (EDD) obligations are imposed for high-risk customers and transactions, including those involving politically exposed persons (PEPs) and high-risk jurisdictions Ukraine - United States Department of State
• Virtual asset service providers must report suspicious transactions to the State Service for Financial Monitoring (SSFM) within a prescribed timeframe, in accordance with Article 18 of the AML Law Ukraine - United States Department of State
• Record retention requirements mandate that virtual asset service providers must store documents and data related to transactions for at least five years after the end of the business relationship Ukraine - United States Department of State
• Beneficial ownership information must be collected and verified by virtual asset service providers, including obtaining information about the ultimate beneficial owner of legal entity customers Ukraine - United States Department of State
• The SSFM has the authority to review and request information from virtual asset service providers, and to impose penalties for violations of AML obligations Ukraine - United States Department of State
• In practice, AML supervision of virtual asset service providers is challenging because the licensing regime is not yet operational, meaning many crypto businesses operate without being registered with the SSFM Ukraine - United States Department of State
• The National Bank of Ukraine imposes its own AML requirements on banks and financial institutions, requiring them to exercise caution when conducting transactions related to virtual assets due to the lack of a legal framework Ukraine - United States Department of State

Enforcement Actions

• The National Bank of Ukraine has issued public warnings about the risks of using virtual assets and has indicated that banks should not facilitate transactions related to virtual assets until the regulatory framework is complete Ukraine - United States Department of State
• Ukrainian law enforcement, including the Cyber Police Department of the National Police of Ukraine, has conducted operations against illegal cryptocurrency activities, including unlicensed exchange operations and fraud schemes Ukraine - United States Department of State
• The Security Service of Ukraine (SBU) has reported investigating cases involving the use of cryptocurrency for financing illegal activities, but specific case outcomes are not consistently published Ukraine - United States Department of State
• The State Service for Financial Monitoring has issued guidance regarding the identification of suspicious virtual asset transactions and has coordinated with international partners on crypto-related investigations Ukraine - United States Department of State
• No public enforcement actions have been taken against licensed virtual asset service providers since no licenses have been issued, creating a compliance vacuum where unlicensed operators face unclear legal consequences Ukraine - United States Department of State
• The US Treasury's OFAC has designated certain Ukrainian and Russian entities under sanctions regulations, but these actions target specific sanctioned parties rather than constituting regulatory enforcement against the Ukrainian crypto market generally Federal Register :: Ukraine-/Russia-Related Sanctions Regulations

Tax Treatment

• No tax guidance has been issued for virtual assets, as the amendments to the Tax Code of Ukraine necessary to establish taxation rules for virtual assets had not been adopted as of 2025 Ukraine - United States Department of State
• The Law of Ukraine "On Virtual Assets" explicitly states that virtual asset taxation matters would be regulated by the Tax Code, but the corresponding amendments to the Tax Code have not been enacted Ukraine - United States Department of State
• Draft Law No. 10225-1 proposes amendments to the Tax Code that would introduce a 5% tax on income from virtual asset operations and exempt personal transactions up to a certain threshold, but this law had not been passed as of 2025 Ukraine - United States Department of State
• As a result of the missing tax legislation, virtual asset transactions are not subject to any specific tax regime, creating significant uncertainty for businesses and individuals involved in crypto activities Ukraine - United States Department of State
• The State Tax Service of Ukraine has not yet issued official guidance on the tax treatment of virtual assets, and taxpayers are left with the general provisions of the Tax Code which do not specifically address digital assets Ukraine - United States Department of State
• There is no VAT treatment established for virtual asset transactions, meaning that businesses accepting crypto payments cannot definitively determine their VAT obligations Ukraine - United States Department of State

Key Gaps & Risks

• The primary market gap is the lack of operational licensing: the Law on Virtual Assets exists but the regulatory framework for issuing licenses and supervising virtual asset service providers is not yet in force Ukraine - United States Department of State
• The absence of Tax Code amendments creates significant tax uncertainty, as businesses cannot determine their tax liabilities for virtual asset operations Ukraine - United States Department of State
• A major gap exists between paper law and practical reality: while the AML law technically covers virtual asset service providers, the SSFM cannot effectively supervise unlicensed entities operating in the market Ukraine - United States Department of State
• Businesses face significant legal risk because operating as a virtual asset service provider is technically illegal without a license, but no licenses are available to obtain — creating a regulatory deadlock Ukraine - United States Department of State
• The National Bank of Ukraine's cautious approach to virtual assets creates banking risk, as Ukrainian banks may refuse to open accounts for crypto businesses or freeze their transactions Ukraine - United States Department of State
• The ongoing war with Russia has created additional compliance risks, as international sanctions compliance is required for businesses dealing with parties in temporarily occupied territories Federal Register :: Ukraine-/Russia-Related Sanctions Regulations
• Even in the temporarily occupied territories of Ukraine, including Crimea, the legal framework of Ukraine continues to apply, meaning that Russian-conducted crypto activity is not legally recognized Law of Ukraine on the Legal Regime on the Temporarily Occupied Territory of Ukraine and Ukraine's Policy towards Russia's Occupation of Crimea | Embassy of Ukraine in the Republic of India
• The lack of clear regulation for initial coin offerings (ICOs), security tokens, and decentralized finance (DeFi) operations represents a significant regulatory gap Ukraine - United States Department of State
• International partners have noted that Ukraine's crypto regulation roadmap has been delayed due to the war, with the full implementation of the virtual asset framework not expected in the immediate future Ukraine - United States Department of State
• The potential adoption of the Ukrainian Adjustment Act in the United States would affect Ukrainian nationals' immigration status in the US but has no impact on Ukraine's domestic virtual asset regulation Text - H.R.3104 - 119th Congress (2025-2026): Ukrainian Adjustment Act of 2025 | Congress.gov | Library of Congress

Sources

• Ukraine - United States Department of State
• Federal Register :: Extension of the Designation of Ukraine for Temporary Protected Status
• Federal Register :: Extension and Redesignation of Ukraine for Temporary Protected Status
• Federal Register :: Public Inspection: Temporary Protected Status: Extension of the Designation of Ukraine
• Federal Register :: Designation of Ukraine for Temporary Protected Status
• Federal Register :: Ukraine-/Russia-Related Sanctions Regulations
• Law of Ukraine on the Legal Regime on the Temporarily Occupied Territory of Ukraine and Ukraine's Policy towards Russia's Occupation of Crimea | Embassy of Ukraine in the Republic of India
• Text - H.R.3104 - 119th Congress (2025-2026): Ukrainian Adjustment Act of 2025 | Congress.gov | Library of Congress
• H.R.3911 - 118th Congress (2023-2024): Ukrainian Adjustment Act of 2023 | Congress.gov | Library of Congress