Navigating Ukraine’s banking system
By Liliane Bivings
Note: KPMG Ukraine Gateway is honored to sponsor this Investors' Guide to Ukraine and support the Ukraine investment community. Please note that our sponsorship of this publication is not an endorsement or implied backing of any companies discussed within this publication or their products or services.
For all the support Ukraine has abroad — even from banks that proudly advertise opening accounts for Ukrainian refugees — you might believe foreign investors could easily move money into the country to support its economy.
Unfortunately, the reality is a little more complex. When it comes to getting bank financing for projects in Ukraine, forget it. Foreign banks aren't keen to lend, and perhaps surprisingly, Ukrainian banks don't lend to foreign companies(even those with Ukrainian partners) due to a variety of legal restrictions.
This changes the investment environment, requiring investors to seek out alternative funding arrangements, including support from international financial institutions, national credit agencies, and — for the especially bold — going it alone and injecting their own financing into promising projects.
For the foreign investor who has come to accept that they'll need to bring their own capital into Ukraine, opening a bank account in another country to do business in Ukraine — the typical route for foreign and institutional investors — can still be a difficult path.
The issue isn't just the war, either. Many banks abroad have long been wary of perceived corruption and anti-money laundering risks in Ukraine. According to Swen Lorenz, a U.K.-based real estate investor currently entering the Ukrainian market, those risks can often be the first topic of conversation in discussions with banks about opening an account to do business in Ukraine.
All of that being said, where there's a will, there's a way. Foreign investors have found that if you put in the work and the time, getting your business in Ukraine up and running with a local corporate bank account is not the insurmountable obstacle some might think.
When it comes to picking a foreign bank with which to do business in Ukraine, there are several banks to consider, such as OTP Bank, Crédit Agricole Bank, Raiffeisen Bank, Ukrsibbank (BNP Paribas Group). According to Lorenz, one bank seemed to be the best fit for his business purposes.
"Raiffeisen Bank was the fastest to respond, they called the next day. Immediate action, absolute clarity on what needed to be done, a complete understanding of the region, and they listened to what we needed and said, ‘yes, we can provide that — here are the fees,’" Lorenz stated.
What has helped Lorenz and other investors make headway is finding that banks typically like to see that you have all your ducks in a row — insurance, a fund administrator, a law firm, and an auditor — before you approach them about opening an account to operate in Ukraine.
In contrast, opening and maintaining your Ukrainian personal account can be relatively easy and painless compared to some other countries, despite some negative stereotypes about Ukraine's banking system.
"It's not uncommon for investors to assume that banking in Ukraine is opaque, unstable, or disconnected from international standards," says Oleg Goshchansky, head of the KPMG Ukraine Gateway initiative. "These perceptions are often shaped more by past crises and recent wartime headlines than by the current reality."
Ukraine's banking sector has been fundamentally reshaped in the post-EuroMaidan Revolution era since 2014. Under the oversight of the National Bank of Ukraine, supervision has tightened, banks are well capitalized, and alignment with EU regulation is roughly 80% of the way there.
For individuals, opening a personal bank account in Ukraine is actually very easy and as simple as just visiting a branch in the country with basic documentation like a passport and a W9 if you're an American citizen.
"For informed investors, the challenge is less about banking risk and more about distinguishing between legacy narratives and current institutional realities," Goshchansky added.
And while the war has presented challenges to the Ukrainian banking sector, institutions have also weathered the storm well and come out more resilient on the other side, having done "everything necessary to protect their people, servers, data, key processes as required by local regulations," says Yuriy Fedoriv, partner and head of financial services at KPMG in Ukraine.
Compared to individual banking, however, the current institutional realities of business banking with Ukrainian banks include hurdles that are mostly bureaucratic in nature, the main one being compliance with anti-money laundering rules, explains Yuriy Katser, partner and head of legal services at KPMG Law Ukraine, who has broad experience in international legal matters.
These rules require disclosing complex ownership and ultimate beneficiary owners. According to Katser, this can be especially tricky for multi-level structures like trusts, partnerships, and foundations.
"In practice, banks typically require a bundle of foreign documents — notarized, apostilled, translated into Ukrainian, and issued within the last 90 days — and often follow up with additional requests," Katser explained.
"From our side at KPMG, it is always a challenge to explain the requirements set by Ukrainian legislation in this respect to foreign investors. This is where local specialists can help avoid unnecessary delays or complications."
One other area to note is that opening bank accounts for investors in the defense and other regulated sectors obviously requires undergoing additional compliance procedures, as well as other factors an investor may not have considered at first glance.
Olena Markarenko, partner in risk consulting and ESG at KPMG in Ukraine, also noted that, beyond having a tendency towards a more conservative risk approach, enhanced background checks and Know-Your-Customer (KYC) procedures are now more thorough due to the additional challenges posed by banking in Ukraine during wartime.
"Beyond the standard areas such as ownership, sanctions, high-risk jurisdictions (including offshore regions), and violations of anti-corruption or anti-monopoly legislation, we also (have to) deeply analyze business connections, especially in the context of the ongoing war," Makarenko noted. This level of scrutiny is needed to ensure that Ukraine maintains a high level of banking vigilance, while banks and businesses strive to manage potential operational and reputational risks.
Not an easy pitch, then, when Ukraine is trying to attract interest from foreign investors who have to contend with necessary institutional barriers.
The good news is that the outlook for foreign investors navigating Ukraine's banking sector is generally positive and getting better.
As Ukraine continues to implement alignment with EU standards, strengthened connectivity with EU financial (authorities) should help to enhance the reliability of financial operations in Ukraine, according to Angela Manolache, advisory partner for KPMG in Romania and head of financial services for KPMG in CEE.
For investors coming from abroad, Ukraine's ability to implement such changes would be a welcome and positive step towards "a more reliable and resilient financial system, with lower operational barriers and clearer, more predictable rules that facilitate investment and commercial activity linked to Ukraine."
This closer integration with the EU also brings its own expectations in terms of transparency and controls, and that means even more documentation, monitoring, and reporting. Reframing this extra layer of bureaucracy from a more positive perspective, Manolache notes that such developments "help reinforce trust for all stakeholders involved."
"Investment projects progress more smoothly when strong governance is paired with practical risk mitigation tools," Manolache observed.
"For Ukraine, that means combining strong, auditable control frameworks (governance, internal controls, reporting) with practical access to guarantees, risk insurance solutions, and trade-finance structures where applicable. These mechanisms can support financing decisions and help banks and investors proceed with more confidence, particularly for longer-term projects."
- Access to finance is limited — Despite support for Ukraine, foreign investors may struggle to get loans or open accounts with foreign banks that avoid lending to Ukraine for a variety of reasons, including concerns about the war, legacy narratives concerning corruption, and anti-money laundering concerns.
- Local banking is possible with a little elbow grease — Corporate accounts with foreign banks (like OTP Bank, Crédit Agricole Bank, Raiffeisen Bank, Ukrsibbank) may be opened if investors provide complete documentation and show they are serious. For individuals, opening a personal bank account in Ukraine is very easy, however, and as simple as just visiting a branch in the country with basic documentation like a passport and a W9 if you're an American citizen.
- Ukrainian banks are resilient — Banking supervision has strengthened since 2014, with banks well capitalized and regulation roughly 80% aligned with EU rules. Contrary to expectations, the biggest headline with foreign investors could well be that the war hasn't disrupted key operations.
- Anti-money laundering and documentation can be the main hurdles to business banking — When working with Ukrainian banks, investors must disclose complex ownership and ultimate beneficiaries, submit notarized, apostilled, translated documents, and respond to lots of follow-up requests. Under these circumstances, investors frequently look to local advisory firms to help navigate such systems.
- Perception vs. reality — Ukraine's banking system is much more reliable and transparent than many assume, with clearer rules, lower barriers, and growing EU alignment.
