01 THE HOUR
05:30
Thursday, 24 February 2022

Military strikes had begun before dawn. Martial law took effect at this hour, by Presidential Decree No. 64/2022. The National Bank of Ukraine issued Resolution No. 18 the same day, partitioning the country's payment channels in a single document.

Cashless hryvnia payments: unrestricted. Cash withdrawals in hryvnia: capped at UAH 100,000 per day, with salaries and social benefits exempt. Cash from foreign currency accounts: prohibited. The exchange rate fixed at 29.2549 hryvnia to the dollar. Cross-border foreign currency payments frozen, with exceptions for critical imports, government mobilization, and entities with special NBU permission.
02 THE SEQUENCE
23 Feb The day before the invasion, the NBU issued a public reassurance. It held a sufficient amount of international reserves, it said, and there was no shortage of cash in the banking system.
24 Feb Resolution No. 18 took effect alongside martial law. ATM replenishment was ordered to proceed without restrictions. The NBU pledged unlimited cash support to banks and committed to unlimited unsecured refinancing, with maturity up to one year and an option to extend by another year. E-money issuance and wallet replenishment were halted.
24 Feb At 11:54 that morning, the NBU posted a notice titled "No Restrictions on Cashless Payments, SEP Working Smoothly." The System of Electronic Payments, the country's interbank settlement infrastructure, was operating without interruption. No restrictions had been imposed on cashless transactions. On the ground, the picture on the other side of the partition was already forming. Queues appeared at ATMs across Kyiv, Lviv, Kramatorsk, and Vinnytsia. One Kyiv resident described reaching a shop at roughly 11 AM and finding the longer line was not for the store but for the ATM beside it. In Kramatorsk, dozens waited by an ATM before it ran out of cash. In Slovyansk, people stood in line outside a bank that had already closed.
25 Feb The NBU disbursed UAH 51.5 billion in emergency refinancing to banks through a new facility: unlimited, unsecured, maturity up to one year. It was the first use of the instrument, approved by Resolution No. 22 the day before. A public notice at 11:50 said banks were replenishing ATMs "to the extent possible." Cashless payments continued without interruption.
27 Feb Three days in. Cash was scarce. A student in Sumy reported that ATMs were not working and everyone was looking for money. Another in Kharkiv said no ATM was dispensing cash. NBU Governor Kyrylo Shevchenko issued a public address to retailers and petrol stations, telling them not to decline card payments and calling the refusal "unpatriotic and unforgivable." Cash handling under martial law, he said, posed "additional risks to everyone."

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03 THE HIDDEN DEPENDENCY

As of the end of 2021, 32.9 percent of the Ukrainian banking system's liabilities were denominated in foreign currency. Resolution No. 18 prohibited cash withdrawals from these accounts entirely, with exceptions for entities supporting government mobilization and those with special NBU permission.

The hryvnia cash ceiling of UAH 100,000 per day, roughly $3,400 at the fixed rate, was generous for daily needs. The foreign currency measure was a prohibition, not a ceiling.

A depositor who held dollars in a Ukrainian bank on the morning of February 24 could see the balance through any working channel. The dollars had not been confiscated or converted. They remained in the account. What the resolution removed was the path from the account to the banknote.

What the resolution removed was the path from the account to the banknote.
04 WHAT STILL WORKED
CASHLESS HRYVNIA PAYMENTS
Unrestricted by Resolution No. 18, paragraph 4. The NBU posted confirmation at 11:54 on February 24. The governor's address to retailers three days later reinforced the directive.
SYSTEM OF ELECTRONIC PAYMENTS
The NBU's interbank settlement system continued throughout the first days without interruption, keeping bank-to-bank hryvnia transfers operational across the country.
INTERNATIONAL CARD NETWORKS
Visa and Mastercard continued to service cards issued by Ukrainian banks. The banking system continued to provide POS terminal infrastructure, as the governor's address confirmed. The networks did not suspend operations in Russia until March 5.
05 THE DOCUMENT
THE DOCUMENT
24 February 2022

NBU Board Resolution No. 18, "On Operation of Banking System Under Martial Law." Issued the day martial law began. In one document it partitioned the domestic payment system: unrestricted cashless transactions alongside capped hryvnia cash, a complete prohibition on foreign currency cash, a fixed exchange rate, and a moratorium on cross-border payments with purpose-based exceptions.

The resolution was amended the same day by Resolution No. 21, then amended more than fifty times through 2023 as restrictions were progressively eased.
06 THE PATTERN LIBRARY
#1 When one retail withdrawal channel closes or fails, demand concentrates on whichever channel is left open, and the capacity of that channel sets what a depositor can obtain.
Observed: Northern Rock 2007, Cyprus 2013, India 2016, Greece 2015, United States 1933, Argentina 2001, Lebanon 2019, Worldpay 2026, TSB 2018, Afghanistan 2021, Nigeria 2023, Square 2023, United States 2025, Fiserv 2025, United States 2021, RBS Group 2012, Soviet Union 1991, Russia 2022, Ecuador 1999, Puerto Rico 2017, Ukraine 2022.
#4 Domestic payment channels can continue while cross-border wire transfer routes fail. Where credit card settlement runs through a separate institution on an independent network, it may persist after the wire transfer channel closes. In some cases the central bank intermediates selected transfers through its own remaining correspondent accounts.
Observed: Iceland 2008, Germany 1931, Belize 2015, Russia 2022, Ukraine 2022.
#9 A payment outage can hit card authorisation and merchant funding as separate faults, so acceptance at the terminal is restored while the money owed to the merchant arrives a day late under its own incident notice.
Observed: Worldpay 2026, United States 2021, Marqeta 2026, Square 2023.
#13 A restriction on access to money can be written by purpose as well as by amount, so a balance that cannot be drawn in general becomes payable when it is used for wages, taxes or relief, and the test applied is what the money is for.
Observed: Germany 1931, Brazil 1990, Ukraine 2022.
#40 Cash withdrawal from foreign currency accounts was prohibited entirely while domestic currency cash remained available under a daily ceiling, so a depositor with balances in both currencies could access one as cash and not the other.
Observed: Ukraine 2022.
CHANGED TODAY: Entries 1, 4, and 13 gained Ukraine 2022. New entry 40 added, on the prohibition of foreign currency cash withdrawal alongside continued domestic currency cash access.