Thank you for the opportunity to speak.

In my presentation I ll focus on restrictive measures

recently introduced in Ukraine under the martial law and overview of the functioning of
Ukrainian court, enforcement systems, public registers in Ukraine.
My partner and good friend Tim Stubs will latter speak about respective restrictions recently
introduced in Russia.

All such restrictions should be taken into account while considering restructuring, insolvency
matters with Ukrainian element.

Also at the begging of my presentation please let me mention that our Ukrainian Dentons team
continue servicing the clients, please rely on our assistance.

The martial law in Ukraine was introduced from February 24, by the President Decree for a
period of 30 days. Yesterday the period was extended for another 30 days.

This decision was made due to the military aggression of the Russian Federation against
Ukraine.

Operation of the Banking System

Same day on 24 February 2022, the National Bank of Ukraine issued the resolution on the
conditions of the banking system’s operation and foreign exchange market’s functioning under
martial law.
Since than NBU issued number of normative acts and guidance aimed to ensure functioning
of the country’s financial system.

Under the NBU resolution Ukrainian banks shall continue to operate subject to number of the
restrictions which include, inter alia, the following:

- Banks shall ensure the uninterrupted operation of their branches unless doing so puts at risk
the lives and health of the public.

- Cash withdrawals from accounts are limited to UAH 100,000 per day (excluding salaries and
social benefits), except for businesses and institutions that ensure the implementation of the
government’s mobilization plans (objectives) and entities that have a special permit from the
NBU.
It is now possible to withdraw foreign currency; however, not more than the equivalent of UAH
30,000 (approx. US$1,000), with the following exceptions:
Businesses and institutions that ensure implementation of the government’s mobilization plans
(objectives) and entities that have a special permit from the NBU are exempt from this limit.
Bank branches located in territories under the threat of occupation by the Russian military may
withdraw foreign currency above this limit if the branch manager approves it.

- It is also prohibited in Ukraine to use any electronic means of payment issued by

international participants of payment systems operating in the Russian Federation or
Republic of Belarus.

- ATMs shall be supplied with cash without any restrictions.

 - Generally all cashless payments can be made without limitation but subject to number of
restrictions.
- Payments to and by the Ukrainian government shall be made without restrictions, in
accordance with legislation governing this special period.
- Ukrainian banks are prohibited from FX trading, with some exceptions, including:
 selling of FX by customers to banks and other financial institutions are not restricted;
 FX currency swap transactions of Ukrainian banks are permitted;
 Purchase of foreign currency are permitted only for carrying out the permitted cross-border
payments.

- The NBU introduced a moratorium on cross-border foreign currency payments from

Ukraine, except for:
 The banks’ own operations, including settlements with international payment systems;
 Purchase of goods of critical import as listed in the governmental regulation (including, among
others, medical goods, petroleum, certain food products);
 Payments by or to IFIs;
 Payments ensuring mobilization plans (tasks);
 Payments under special permits by the NBU;
 Payments to diplomatic representations, consulates of Ukraine abroad.

- The exchange rates for foreign currencies are fixed [as at February 24, 2022].

- The NBU shall provide unsecured refinancing to banks to maintain liquidity .

- Issuance of e-money, replenishing e-wallets with e-money, and e-money distribution is

suspended.

- Any currency transactions in RUB and/or with persons residing/registered in Russia or

Byelorussia are prohibited.

In practice some of the permitted transactions still could be unavailable. But generally banking
system, payment system operate well in Ukraine.

Also NBU released the banks from the liability for breaches of prudential standards, deadlines
for reporting; if such breaches were caused by the negative impact of the military aggression
against Ukraine.

OPERATION OF THE CAPITAL MARKET

The principal regulator for the capital market in Ukraine is National Securities and Stock
Markets Commission.
Under the decision of the Commission, circulation of securities in Ukraine are temporary
suspended, except for:
-Operations with government military bonds and other government securities.
-operations necessary for carrying out the monetary and credit policy of the NBU.
 Commission also suspended certain procedural actions in respect of violations of the laws in
respect of (i) consumer rights protection; (ii) capital markets and organized commodity
markets, (iii) anti-money laundering.

The submission deadlines of reports by capital market participants has been extended.

OPERATION OF UKRAINIAN COURTS

Re: operation of Ukrainian courts during martial law – according to the recommendations of
the Council of Judges of Ukraine, courts in Ukraine should determine the regime of their work
depending on the situation in their regions.

Certain Ukrainian courts suspended their work (such as courts in Karkiv, Zhitomir, Zaporizhia);
most of the court hearings are rescheduled (in particular on the debt recovery, insolvency); but
still number of urgent hearings are undergoing. The Supreme Court of Ukraine continues to
operate.

PUBLICK REGISTER; REGISTRATION PROCEDURES

Ukraine is well unowned with well developed digital public registers, including court register,
encumbrance register, unified register of the enterprises, real estate register. No publick
access to such registers is available as of now. Notably that alternative court register has been
recently launched.

In many cases registration procedures required by law are not available (such as corporate
actions, RE tittle registration) , to be checked on case by case basis.

Seizure Law

On March 3, 2022 the Parliament of Ukraine adopted the Law “On the Basic Principles of
Compulsory Seizure in Ukraine of Objects of Property of the Russian Federation and Its
Residents” (the Seizure Law).

On March 3, 2022, the Cabinet of Ministers of Ukraine adopted the Resolution, which
introduces a moratorium on the performance of obligations to Russia and its residents.
The moratorium applies to the following entities and persons (“Qualified Persons”):
 The Russian Federation
 Citizens of the Russian Federation
 Legal entities established and registered under the laws of the Russian Federation
 Legal entities established and registered under the laws of Ukraine, whose ultimate beneficial
owner \ shareholding of 10 percent or more is the Russian Federation, a citizen of the Russian
Federation, or a legal entity established and registered under legislation of the Russian
Federation
The moratorium prohibits:
1. Performance (both voluntarily and through enforcement) of monetary and other obligations vis-
a-vis the Qualified Persons;
2. alienation of real estate objects, securities, other assts by Qualified Persons (as defined
above);
All transactions in violation of the moratorium (including those envisaging the future transfer of
properties) will be considered null and void.

Under the moratorium lenders (creditors) who fall within its scope face serious issues with
repayments in Ukraine.

If creditors hold security provided by a Qualified Persons, enforcement against such security
may be unavailable. Any transactions with Qualified Persons should be carefully analyzed in
view of the moratorium.

FORCE MAGEOUR

On 28 February in view of the current situation in Ukraine, the Chamber of Industry and
Commerce of Ukraine (CCI) has taken the decision to simplify the certification procedure of
force majeure.
The Chamber of Commerce has published a standard official letter certifying force majeure
in Ukraine. Companies can simply print it out as evidence of force majeure.
The letter serves as evidence of “force majeure circumstances: military aggression of the
Russian Federation against Ukraine, which led to the imposition of martial law."
Under the letter, the chamber of Commerce confirms that “these circumstances from February
24, 2022 until their official ending, are extraordinary, unavoidable and objective circumstances
for business entities and / or individuals under the contract, or statutory obligations prescribed
by law
the due fulfillment of which became impossible due to the occurrence of such force majeure
circumstances.”

Under Ukrainian law, force majeure circumstances are extraordinary and unavoidable
circumstances, which objectively prevent performance of contractual obligations or obligations
imposed in legislation. Among such circumstances, the law lists military actions, general
military mobilization, declared or undeclared war, and several other events.
Governing law of your contract matters - please consider checking your contractual provisions
in respect of force majeure, including in respect of the notification requirements.

In case you cannot download the letter from CCIU website, you can also access
the Ukrainian or English version on our platform. Please contact us in case any help is
required in relation to above, we stand by to assist.