On September 22, 2025, the National Bank of Ukraine (NBU) issued a statement confirming that Trustee Global UAB had provided payment financial services in Ukraine, subject to licensing, through the Trustee Plus application. The regulator has banned the company from providing them to Ukrainian citizens until it receives the relevant permit.
According to Vadym Hrusha, CEO of Trustee, the NBU initially identified seven potential violations. However, after an inspection and explanations from the company, the regulator made a negative decision on only two. Namely, the provision of access to the P2P platform and euro transfers between users.
In a conversation with Incrypted, Trustee stressed that the NBU did not ban Trustee’s activities, but “only objected to two points in the structure of its services”.
In addition, Vadym Hrusha assured that clients’ assets are safe, and there are no restrictions for existing users residing in Ukraine and conducting transactions with crypto assets. As a reminder, the company stopped registering new clients in the country back in May.
However, what does this decision of the National Bank mean in general, and are P2P transfers of cryptocurrency users in Ukraine at risk? Lawyers interviewed by Incrypted noted that it is an important warning for the entire market.
“This is a certain signal that the NBU is closely monitoring non-bank financial applications and reacts harshly if such entities provide financial payment services without licenses,” explained Ihor Mlechko, managing partner of ASA Group.
It is worth noting that Trustee itself also said that the regulator’s decision has a broader impact on the crypto market, creating “a negative precedent […] effectively banning P2P interaction between users”.
According to the company’s CEO, the situation around Trustee Plus highlights the lack of a full-fledged regulatory framework in Ukraine, and further pressure on crypto firms without the adoption of specialized legislation could jeopardize the industry’s integration into the financial system.
It is worth noting that the situation with the full legalization of the crypto market in Ukraine has long remained uncertain. The relevant legislation has been under development or rewriting for years.
Recently, in September 2025, the Verkhovna Rada approved the draft law “On Virtual Assets” in the first reading. However, this is not a guarantee of quick adoption of the regulation — Danylo Hetmantsev, the head of the Parliamentary Committee on Finance, Taxation and Customs Policy, has already stated that the document is awaiting many amendments.
Ihor Yasko, attorney and managing partner at Winner Law Firm, said:
“Any foreign services that work with payment or crypto transactions for Ukrainian citizens must comply with Ukrainian regulatory requirements and obtain a license, otherwise they risk being banned.”
At the same time, Ella Nelga, associate at Juscutum’s Business Support Practice, noted that “the NBU’s decision is not a ban on P2P in Ukraine, but specifically refers to the company’s activities without proper authorization”.
She added:
“The Law of Ukraine “On Payment Services” stipulates that to provide payment services, a company must obtain a license or, if it is a branch of a foreign payment institution, be accredited by the NBU. The company must also ensure a proper corporate governance and risk management system, ensure that users’ funds are kept separate from its own, insure or guarantee users’ funds, and agree on the ownership structure with the NBU.”
The lawyers noted the following implications of the NBU’s decision for users and the market:
- Ukrainian citizens are restricted from using P2P services through Trustee Plus within the jurisdiction of Ukraine, but this does not mean that they are prohibited from using P2P transfers in general;
- This decision may become a precedent for other foreign services that work with Ukrainian users without licenses.
It should be noted that we asked several market representatives to share their position, but most of them said they did not comment on this topic.
Meanwhile, MEXC Research’s Chief Analyst Shawn Young stressed that AML/KYC procedures, tax regulation, and interaction with the banking sector remain the key challenges.
“Ukraine is at the stage of forming a full-fledged regulatory framework, which creates the basis for a more transparent and structured market […] In case of insufficient coordination between regulators and business, there may be temporary restrictions on the operation of P2P services or stricter requirements for users,” said Young.
However, the expert noted that the exchange sees these processes “as a stage of building the rules of the game rather than a threat to business.” According to him, integration with European standards can provide additional guarantees to users and investors and open a new stage in the development of P2P services in Ukraine.