Ukraine Compliance Report

Generated 2026-09-22

Prohibited

Regulatory Overview

Regulatory Status: Outright ban on crypto ownership, trading, or mining
Key Regulator(s): Bank of Ukraine, Ministry of Digital Transformation of Ukraine, Reporting Authority
Primary Legislation: While the VA Law is in force, its full implementation, particularly the practica, This is a cornerstone of the VA Law and is largely aligned with international st, More granular classification and regulation of different crypto-asset types (e.g, Signed into Law by President Zelenskyy: March 16, 2022, Crypto is legal in Ukraine, with a foundational law passed in 2022 establishing, The law establishes that virtual assets are intangible goods and defines two cat, The law for virtual assets entered into force, but the key provisions regarding, Ukrainian law enforcement, including the Cyber Police Department of the National, Draft Law No. 10225-1 proposes amendments to the Tax Code that would introduce a, The primary market gap is the lack of operational licensing: the Law on Virtual, A major gap exists between paper law and practical reality: while the AML law te, The lack of clear regulation for initial coin offerings (ICOs), security tokens,, International partners have noted that Ukraine's crypto regulation roadmap has b, Text - H.R.3104 - 119th Congress (2025-2026): Ukrainian Adjustment Act of 2025 |, H.R.3911 - 118th Congress (2023-2024): Ukrainian Adjustment Act of 2023 | Congre
Travel Rule: Not adopted
Tax Reporting: Law of Ukraine "On Virtual Assets" (adopted September 8, 2022, effective December 15, 2022): This law provides a legal framework for virtual assets, defining them, their types, and the regulatory bodies. It legalizes the virtual assets market but did not introduce specific tax rules for virtual assets. It explicitly stated that the taxation of virtual assets should be regulated by amendments to the Tax Code of Ukraine.. Reference: Закон України "Про віртуальні активи" (Law of Ukraine "On Virtual Assets"). You can find the official text on the website of the Verkhovna Rada of Ukraine (the Ukrainian parliament): https://zakon.rada.gov.ua/laws/show/2074-IX. Current Interpretation: Profits derived from virtual asset transactions (e.g., selling cryptocurrency for fiat currency, exchanging one cryptocurrency for another at a profit, receiving crypto as payment for services) are generally treated as other investment income or simply other taxable income.. Taxable Event: A taxable event occurs when a gain is realized (e.g., sale, exchange, or use of crypto for goods/services where its value has increased since acquisition).. Personal Income Tax (PIT): 18%

Key Facts

aml Law of Ukraine No. 361-IX "On Preventing and Counteracting Legalization (Laundering) of Criminal Proceeds, Terrorist Financing and Financing the Proliferation of Weapons of Mass Destruction" (dated December 6, 2019, with subsequent amendments). This is the foundational AML/CFT law in Ukraine, bringing the country's framework closer to FATF recommendations and the EU's 4th and 5th AML Directives. It designates "virtual asset service providers" as "reporting entities" (subjects of primary financial monitoring). Law of Ukraine No. 2074-IX "On Virtual Assets" (dated February 17, 2022). This law defines virtual assets and virtual asset service providers (VASPs) in Ukraine. While its full implementation regarding licensing and specific regulatory oversight was initially delayed due to martial law, its principles establish the legal framework for virtual assets and clarify the roles of regulatory bodies. It reinforces that VASPs are subject to AML/CFT requirements under Law No. 361-IX. Exchange between one or more forms of virtual assets. Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets. Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset. For Individuals: Obtain and verify the customer's identity, including full name, date of birth, place of birth, address, identification number (where applicable), and details of the identity document (series, number, date of issue, issuing authority). Verification must be based on reliable, independent source documents, data, or information.
custody Law of Ukraine "On Virtual Assets" (Закон України "Про віртуальні активи"): This is the primary law, adopted in September 2021 and signed into law by the President in March 2022. It establishes the legal framework for virtual assets in Ukraine, defines types of virtual assets, and outlines the activities of Virtual Asset Service Providers (VASPs). Law of Ukraine "On Preventing and Counteracting Legalization (Laundering) of Criminal Proceeds, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction" (AML/CFT Law): This law was amended to include VASPs as subjects of primary financial monitoring, bringing them under the strict AML/CFT regime. Reference: Law of Ukraine "On Preventing and Counteracting Legalization..." (in Ukrainian) National Securities and Stock Market Commission (NSSMC - НКЦПФР): The primary regulator for virtual assets, especially those secured by currency, valuables, or property rights, and for most VASP activities. National Bank of Ukraine (NBU - НБУ): Regulates virtual assets secured by monetary values. State Financial Monitoring Service of Ukraine (SFMS - Держфінмоніторинг): Responsible for AML/CFT oversight and financial intelligence. Ministry of Digital Transformation (MinDigital): Responsible for developing state policy in the field of virtual assets. Mandate: The Law "On Virtual Assets" mandates that any entity providing virtual asset services, including custody services, must obtain a permit (дозвіл). This permit functions similarly to a license.
enforcement Legal Basis: Primarily the International Emergency Economic Powers Act (IEEPA). Legal Basis: Criminal Code of Ukraine (Кримінальний кодекс України), Code of Administrative Offenses of Ukraine (Кодекс України про адміністративні правопорушення).
general Virtual Assets: A general category of intangible property represented in digital form, which can be stored, managed, and transferred using distributed ledger technology or similar. Virtual Assets that are Securities: These are virtual assets that, by their economic substance and the rights they grant, meet the definition of any type of security as per the capital markets legislation. The nature of the rights conferred by the token: Does it represent ownership (e.g., shares), debt (e.g., bonds), a right to a share of profits, a right to receive payments, or participation in a collective investment scheme? The economic purpose of the token: Is it issued primarily for investment purposes with an expectation of profit from the efforts of others, rather than solely for utility within a specific network or access to a product/service? Transferability: Is it intended to be freely transferable and traded on secondary markets? Security Tokens: Tokens that represent traditional securities like: Shares: Representing equity ownership in a company. Bonds: Representing debt obligations.
licensing Define virtual assets and their legal status. Regulate the market for virtual assets. Protect the rights of participants in the virtual asset market. Establish anti-money laundering and counter-terrorist financing (AML/CFT) requirements for virtual asset service providers (VASPs). National Bank of Ukraine (NBU): Responsible for the regulation of virtual assets secured by currency (fiat-backed stablecoins) and for payment services involving virtual assets. Ministry of Digital Transformation of Ukraine (MinDigital): Responsible for the regulation of other types of virtual assets, including licensing of Virtual Asset Service Providers (VASPs). State Financial Monitoring Service of Ukraine (SFMS): Responsible for financial monitoring of transactions with virtual assets and ensuring compliance with AML/CFT legislation. While the VA Law is in force, its full implementation, particularly the practical licensing mechanism, depends on the adoption of secondary legislation (resolutions, procedures, and detailed requirements) by the NBU and MinDigital.
sanctions Key Impact on Crypto: OFAC has explicitly targeted cryptocurrency transactions and entities facilitating sanctions evasion, particularly those linked to Russia. It has sanctioned crypto mixers (e.g., Tornado Cash), crypto exchanges (e.g., Garantex, SUEX), and specific individuals involved in facilitating illicit finance. Sanctioned Entity Screening: Strict obligation to screen all customers (KYC), beneficial owners, and transaction counterparties against the Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions lists (e.g., Non-SDN Menu-Based Sanctions List - NS-MBS). Asset Freezes: Any virtual assets owned or controlled by sanctioned persons must be blocked and reported to OFAC. Prohibited Transactions: Prohibition on engaging in any transactions, directly or indirectly, with sanctioned individuals, entities, or in relation to sanctioned jurisdictions/territories (e.g., Crimea, occupied territories of Ukraine). Geographic Restrictions: Prohibitions on engaging in certain economic activities within Crimea, Sevastopol, and the occupied territories of Donetsk, Luhansk, Kherson, and Zaporizhzhia regions of Ukraine. Reporting Obligations: Mandatory reporting of blocked assets and rejected transactions to OFAC. OFAC Main Website: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information Russia-Related Sanctions Program: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russia-related-sanctions
securities Crypto and virtual assets in Ukraine currently lack a comprehensive, dedicated securities-specific regulatory framework; the existing legal architecture regulates traditional securities, and the Law of Ukraine "On Virtual Assets" has been adopted but implementation remains incomplete. About us – НКЦПФР, General Legal Framework | Baker McKenzie No entity has been licensed under a specific digital asset securities regime, as no such dedicated licensing framework for crypto-asset securities has yet entered into force; licensing currently applies only to traditional securities market activities. Securities issue – НКЦПФР, General Legal Framework | Baker McKenzie Practical reality: crypto businesses operate in a legal gray zone, with tax and securities treatment unresolved, though the NSSMC is modernizing capital markets regulation in line with EU standards, including new market abuse and disclosure rules effective from 1 January 2026. General Legal Framework | Baker McKenzie Ukraine is a member of IOSCO since 1996, and the NSSMC is not a signatory to the IOSCO Multilateral Memorandum of Understanding, limiting international cooperation mechanisms. Investment Climate Statements - U.S. State Department The National Securities and Stock Market Commission (NSSMC) is the state collegial authority responsible for regulation of the securities market in Ukraine, organized commodity markets, and other capital market instruments. About us – НКЦПФР The NSSMC adopts legally binding regulatory acts for market participants, licenses professional activities, registers securities issues, and oversees issuers' compliance with disclosure requirements; its website is https://www.nssmc.gov.ua. About us – НКЦПФР The National Bank of Ukraine (NBU) and the NSSMC share oversight over different groups of financial institutions, with the NBU supervising insurance, leasing, factoring, credit unions, credit bureaus, pawnshops, and other financial companies, while the NSSMC regulates private funds including pension funds, construction financing, and real estate transactions. Who regulates banking and financial services | Baker McKenzie, Investment Climate Statements - U.S. State Department The State Service of Financial Monitoring is the central body of the executive power acting as the financial intelligence unit, with the NBU and NSSMC acting as additional second-tier agencies for regulatory and oversight functions over initial financial monitoring institutions. Who regulates banking and financial services | Baker McKenzie
stablecoin Law of Ukraine "On Virtual Assets" (№ 2724-IX): Adopted by the Verkhovna Rada (Parliament) on 6 September 2022 and signed into law by the President on 15 March 2023. This is the foundational law. Link to official text (Ukrainian) Note: While the law is enacted, its full operation depends on amendments to tax legislation and the adoption of various sub-regulatory acts by the NBU and NSSMC. Law of Ukraine "On Payment Services" (№ 1591-IX): Adopted on 30 June 2021. This law defines electronic money and payment services. The Law "On Virtual Assets" explicitly distinguishes virtual assets from electronic money under this law. National Bank of Ukraine (NBU): Responsible for regulating virtual assets that are secured by currency values (e.g., fiat-pegged stablecoins) and for supervising virtual asset service providers (VASPs) that provide services with such assets. It also oversees payment services and electronic money. National Securities and Stock Market Commission (NSSMC): Responsible for regulating virtual assets that are secured by other virtual assets or by property rights, and for virtual assets that qualify as security tokens. Ministry of Digital Transformation: Instrumental in developing the virtual assets legal framework and promoting blockchain technology. Virtual Assets vs. Electronic Money/Securities: The Law "On Virtual Assets" categorizes virtual assets as intangible goods, explicitly stating that virtual assets are not legal tender, electronic money, or securities.
status 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 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 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
tax Law of Ukraine "On Virtual Assets" (adopted September 8, 2022, effective December 15, 2022): This law provides a legal framework for virtual assets, defining them, their types, and the regulatory bodies. It legalizes the virtual assets market but did not introduce specific tax rules for virtual assets. It explicitly stated that the taxation of virtual assets should be regulated by amendments to the Tax Code of Ukraine. Reference: Закон України "Про віртуальні активи" (Law of Ukraine "On Virtual Assets"). You can find the official text on the website of the Verkhovna Rada of Ukraine (the Ukrainian parliament): https://zakon.rada.gov.ua/laws/show/2074-IX Current Interpretation: Profits derived from virtual asset transactions (e.g., selling cryptocurrency for fiat currency, exchanging one cryptocurrency for another at a profit, receiving crypto as payment for services) are generally treated as other investment income or simply other taxable income. Taxable Event: A taxable event occurs when a gain is realized (e.g., sale, exchange, or use of crypto for goods/services where its value has increased since acquisition). Personal Income Tax (PIT): 18% Military Levy: 1.5% Total Effective Rate: 19.5% on the realized profit (income minus documented expenses). Deductible Expenses: The documented cost of acquiring the virtual asset, as well as transaction fees, should generally be deductible from the proceeds to determine the taxable profit.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile