Ukraine – CM P

Update BRP Country Manual Products

Ukraine

without License out of Service Provider’s Country of Establishment (DEF, RO & BT)

Definitions & Concepts, Regulatory Overview and Behaviour Template

The Country Manual has been reviewed to ensure to ensure that the content of all the documents remain accurate and up to date.

While the situation in Ukraine continues, we expect the frequency and reliability of alerts regarding regulatory developments in Ukraine to remain affected. Please note, therefore, that regulatory practices and interpretations may change without prior notice.

Material changes

In alignment with the Country Manual Private Banking (CM PB), the provision of Macroeconomic information/reports and Investment research and Financial Analysis documents/reports as well as other publications and other marketing material referring to specific financial products made on a generic basis or based on the specific investment profile of one recipient are only permitted on an occasional basis onshore in Ukraine (at target). The CM P BT therefore now provides the answer “Grey zone” in the relevant onshore scenarios.

In further alignment with the CM PB, the provision of investment services is only permitted on an occasional basis onshore in Ukraine (at target). The CM P BT therefore now provides the answer “Grey zone” in the relevant onshore scenarios.

With regards to advisory services, a distinction is no longer made between the provision of advisory services based on a written advisory agreement and such provided without formal basis in relation to the distribution of financial products. In the CM P BT, the two situations “advice within an ongoing advisory agreement” and “advice without/outside the scope of an ongoing advisory agreement (spot advice)” are therefore now treated equally.

With regards to execution-only services, in alignment with the CM PB, it is recommended that such services are provided by foreign (unlicensed) service providers in Ukraine (at target), with the additional recommendation that the order be passed to the service provider’s bank in its country of establishment for execution.

Please further note that, in alignment with the CM PB, the provision of investment services, as well as marketing activities by foreign (unlicensed) service providers should not involve financial products admitted for circulation on the local capital markets. Any Services related to such domestic Securities as well as other Ukrainian law financial instruments (Derivatives and Derivative Contracts) should be provided by Ukrainian licensed financial intermediaries only.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, August 22^nd, 2025