Currency control in 2025: automation of oversight, cooperation between banks and the Tax Service, key changes for exporters and importers.

In 2025, currency supervision and foreign economic activity in Ukrainian companies are undergoing a reboot: the National Bank of Ukraine (NBU) and the State Tax Service (STS) are introducing fundamentally new interagency communication and reporting procedures with commercial banks. This is in line with currency liberalization processes, the growth of foreign trade operations, and the adoption of a risk-based approach to oversight.

Core regulatory framework and recent changes
In summer 2025, the NBU approved new rules for currency supervision. Banks received clear algorithms for handling currency control — especially for complex transactions, guarantees, import and export of goods. The key points are:

• completion of currency control not just after receipt of funds but also after receiving documents/guarantees from correspondent banks (non-residents);
• clarified requirements for supporting documentation;
• rules for refunding mistakenly transferred funds.
  The NBU also eased some FX restrictions: business can now repatriate dividends for 2023 (up to €1 million per month), aimed at attracting investment without excess currency demand.

Bank, STS and communication mechanisms
Banks’ new role as agents of currency supervision covers not just checking payment deadlines, but also monitoring risk for each client transaction. Banks, under new algorithms, must:

• promptly inform the STS of late payments, violations or problems with FX proceeds or imports;
• report “red flags” for enhanced financial security;
• increase automated notifications (via electronic channels) and reduce paperwork.
  In turn, the STS intensifies analytics — all bank data go into a unified database for risk analysis. Priority is given to informal export/import schemes, payment splitting, use of shell nonresident companies, suspicious transactions.

Risk-based approach and control algorithms
The prevalence of risk assessment in currency supervision leads to these scenarios:

• not all formal violations lead to sanctions if there’s economic justification and no evidence of money laundering;
• before notifying the STS, banks run operations through risk-scoring criteria;
• the main trigger is not merely payment delays, but mismatches between declarations, invoices, purpose of payment, counterparty data.

Key business risks and issues

1. Insufficient documentation — if a company doesn’t provide all supporting papers, the bank notifies the STS;
2. Atypical payment behavior — splitting amounts, frequent receipts from different countries, unusual counterparties;
3. Breach of payment deadlines — penalty is 0.3% per overdue day (max 100%);
4. Late import settlements — companies may apply to the Ministry of Economy to extend the period or resolve issues in court/arbitration.

How to minimize business risks

• Ensure full legal support for foreign contracts: agreement, invoices, customs declarations, correspondence;
• Provide prompt explanations to the bank, especially at compliance officer request;
• Use clear payment purposes;
• Avoid splitting payments or wiring funds to/from suspicious jurisdictions;
• Monitor settlement periods and seek official government conclusions in case of delays.

2025 currency control: new approaches
The trend is to redefine banks’ roles: they are now the linchpin in automated currency control mechanisms.

• More focus on e-documents and real-time data transmission;
• Standardized requirements (all banks use the same formats and references);
• Reduced subjectivity: risks are algorithmically analyzed, not checked manually;
• Fast response: just hours after an incident, the system notifies the STS, minimizing delays for law-abiding companies.

One-stop window for business
In 2025, a “single window” for bank and business currency reporting is launched. Clients can track their status for any FX operation, view contract histories, and bank/STS correspondence.
Digital solutions, personal accounts, request/response templates, and integration with Diia Business increase transparency, convenience, and efficient case closure.

Expected effect for the economy

• Foreign trade liquidity and turnover rise thanks to less paperwork;
• Financial monitoring risks drop for transparent businesses, while risky transactions are rapidly caught;
• More companies can export/import without artificial barriers.

Conclusions
Currency control in 2025 is focused on preventing genuine, not just formal, risks. Integration between the STS, NBU, and banks into a unified digital ecosystem, along with new communication algorithms, boosts market transparency and convenience, and gives business fast compliance without unnecessary bureaucracy. Timely adaptation to new rules and improving internal compliance culture are no longer trends, but survival standards in today’s Ukrainian FX market.

Author: Maksym Bagniuk, Head of Tax and Customs Practice, WINNER Law Firm.
If you have questions or issues related to currency supervision, foreign trade contracts, banking algorithms for FX operations, or appealing actions of supervisory authorities — contact the lawyers and experts at WINNER Law Firm. Professional support at every stage of currency compliance will protect your business and help avoid risks in today’s regulatory environment.