Dear client,
We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:
UKRAINE
| SOURCE OF CHANGES | ANSWERS |
| Law/Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | No |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
While there have been no material changes in the approach of the Ukrainian regulation on licensing requirements for cross-border financial business, Ukraine has generally adopted a number of restrictions in response to the invasion of Ukraine by the Russian Federation (“martial law limitations”) which are of a capital-control nature. They have been dynamic in nature and may be expected to continue to change in the future. Accordingly, they should be checked carefully each time a particular operation is intended to be carried out. The more salient restrictions with implications on currency control (of relevance for cross-border purposes) are described in the manuals. In particular, such martial law limitations concern (but are not limited to) cross-border payments.
Non-material changes
Some comments/conditions have been reworded, additional references to applicable law/regulation have been made in order to provide more clarity and to reflect the current regulatory situation more accurately. Further non-material changes have been made throughout the documents.
Implications for business relations with third parties
With respect to the provision of documentation to the EAM (such as documentation on the Bank’s banking and investment services, investment research and financial analysis or recommendation lists), our Country Manual now distinguishes between the provision to the EAM for remittance to the end client on one hand and the provision to the EAM for the EAM’s own professional purposes on the other hand. The answers have been amended accordingly.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “UKRAINE” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Best regards,