The National Bank of Ukraine (the “NBU”) adopted Resolution No.654 dated 1 October 2015 “On Ensuring Implementation and Monitoring of Efficiency of Personal Special Economic and Other Restrictive Measures (Sanctions)” (the “Resolution 654”) aimed at implementing, within Ukrainian banking and finance market, certain financial sanctions adopted by the National Security and Defense Council of Ukraine (the “NSDCU”) in September 2015[1].

Sanctions of the NSDCU apply to more than 350 individuals and more than 100 legal entities, including non-resident individuals and legal entities.

Pursuant to Resolution 654, Ukrainian banks and other financial institutions are required to provide the NBU with information on bank accounts and operations of addressees of the sections and to update such information on a monthly basis.

In furtherance of the NSDCU decision, the Ukrainian banks and financial institutions are obliged to implement the following financial measures (depending on a particular type of sanctions assigned by the NSDCU to a particular addressee):

• freezing of funds on bank accounts;
• suspension of performance of economic and financial obligations towards the addressees of sanctions;
• suspension of performance of economic and financial commitments (granting loans, financial aid, guarantees, purchase of securities);
• prevention of funds outflow from Ukraine;
• suspension of any financial transactions (including any foreign currency conversion transactions);
• prohibition on establishment of any business relations with addressees of sanctions.

Resolution 654 entered into force on 2 October 2015 and shall remain in force for so long as the above sanctions of the NSDCU apply.