The NBU has limited the access of banks with sub-sanctioned owners to certificates of deposit: new rules from December 1

The National Bank of Ukraine is introducing new restrictions for financial institutions whose owners include persons under sanctions. From December 1, 2026, such banks will lose the ability to purchase NBU certificates of deposit without a separate permit from the regulator.

The innovations apply to banks whose significant shareholders are under sanctions, as well as institutions whose shareholders the regulator has required to alienate their shares.

In particular, such banks will be restricted from placing funds in National Bank certificates of deposit through tenders and purchasing them on the interbank market.

Which banks are subject to restrictions

The new rules provide for restrictions for three categories of financial institutions.

1. Banks with significant shareholders under sanctions.

Such institutions will be able to restore access to transactions with certificates of deposit only by a separate decision of the NBU Committee on Banking Supervision.

When making a decision, the regulator will take into account the impact of the relevant bank on the stability of the banking system of Ukraine.

2. Banks whose owners have been deprived of voting rights.

These are cases when the National Bank temporarily prohibited a sanctioned shareholder from exercising voting rights and transferred the relevant powers to a trustee.

Resumption of operations with deposit certificates for such institutions is also possible by decision of the NBU’s specialized committee.

In doing so, not only the stability of the banking system will be taken into account, but also the need to protect the interests of depositors and creditors.

3. Banks whose owners the NBU has ordered to sell shares.

To restore access to deposit certificates, such institutions must comply with the regulator’s requirement to alienate the stake and form a new ownership structure approved by the National Bank.

When will the new rules come into effect

The restrictions will come into effect on December 1, 2026.

The relevant provisions were included in the NBU Resolution No. 22 of February 24, 2022, which defines the features of the banking system’s operation under martial law.

What are NBU certificates of deposit

National Bank certificates of deposit are a financial instrument with which banks can temporarily place free funds in the NBU and receive interest income.

The use of such certificates allows financial institutions to manage their own liquidity.

The new rules will restrict access to this instrument for banks with sanctioned owners and institutions that have not fulfilled the regulator’s requirements for changing the ownership structure.

At the same time, the restrictions do not mean the automatic termination of the activities of such banks. They relate to certain operations with National Bank certificates of deposit.