Lifting the seizure of bank accounts during martial law: instructions

Under martial law in Ukraine, the arrest (freeze) of bank accounts is a compulsory enforcement measure that restricts the movement of funds in current, card, or deposit accounts and is applied pursuant to writs of the enforcement service or a court order. In this article, you will learn how to lift an arrest from accounts fully or partially — from the grounds for blocking and access limits to a step-by-step procedure for contacting the bank, appealing the actions of the enforcement officer, and protecting social payments.

We also look separately at pre-trial investigation timelines and the maximum terms of an arrest, as well as procedural specifics under martial law, when rules may vary depending on the region and level of restrictions. Clear instructions will help you retain access to essential funds and protect your rights in the most challenging circumstances.

What is an account arrest during wartime

The concept of arrest as compulsory enforcement of judgments

A bank account arrest is a coercive measure aimed at ensuring a debtor’s obligations to creditors or the state are fulfilled by restricting the movement of funds in current, card, deposit, and other accounts. Under the Law of Ukraine “On Enforcement Proceedings,” an enforcement officer issues a ruling (postanova) on arrest, which serves as the basis for the bank to stop any debit transactions on the account, except those that are non-arrestable. Even in peacetime, this procedure is quite complex and requires strict adherence to deadlines, service of documents, and proper documentation of interactions between the enforcement officer and the bank.

During war, the state expands protections of citizens’ financial interests by introducing additional rules for access to funds. This helps avoid extreme financial hardship and reduce social tension.

Why the issue is relevant under martial law — changes in the law

Following the introduction of martial law, the government adopted a number of regulatory changes to minimize negative effects on the economy and vulnerable groups. Cabinet of Ministers Resolution No. 198 of March 2, 2022 authorized banks to disregard enforcement rulings on arrest insofar as necessary to ensure a client’s minimum needs. Later, Resolution No. 581 of May 6, 2023 clarified a limit equal to two minimum wages for withdrawing funds from frozen accounts. These restrictions apply only for the duration of martial law and cover all bank accounts held by individuals, regardless of the bank’s form of ownership or the account type.

Additional procedural rules may also simplify the way certain actions of the enforcement service are appealed (depending on the type of complaint and the procedural route). This can speed up the protection of a debtor’s right to access essential funds.

On what grounds an arrest is imposed

Enforcement and court proceedings

The first ground for arrest is the existence of an enforcement document — a writ of execution, a court order, a notarial writ of execution. Enforcement proceedings are opened at the creditor’s request, after which a state or private enforcement officer issues an arrest ruling. This ruling is sent to the bank in electronic or paper form, and the bank must restrict fund movements. Under the Enforcement Proceedings Law, the bank must stop any debit transactions no later than the next business day after receiving the ruling.

An arrest remains in force until it is lifted on statutory grounds (for example, after completion/termination of enforcement, on the basis of an enforcement officer’s ruling, or by a court decision). Therefore, it is important to initiate the lifting procedure rather than rely on the arrest “expiring” by itself.

Criminal cases, suspicion of financing

An arrest may also be imposed within a pre-trial investigation and criminal proceedings. The Security Service of Ukraine, NABU, or the State Bureau of Investigation may obtain through a court temporary access to the accounts of persons suspected of terrorist financing, money laundering, corruption, and other serious crimes. In such cases, restrictions remain until the court issues a final decision. The pre-trial investigation period cannot exceed 12 months, with possible extension upon the prosecutor’s motion; absent extensions, the arrest may be lifted.

For added security, banks conduct independent checks of clients, allowing risky transactions to be detected even before formal proceedings begin. This prevents overloading law-enforcement agencies.

Bank preventive measures

Banks may apply internal preventive measures — from “freezing” accounts upon detection of suspicious transactions to full blocking by the anti-fraud service. These measures are not an arrest in the legal sense but temporarily restrict access to funds. The client has the right to demand explanations and appeal a bank’s actions to the NBU or in court.

These procedures are often streamlined for rapid response to financial fraud risks, but banks must not violate clients’ rights. Consumer protection rules for financial services guarantee the right to prompt unblocking.

How to check whether an arrest exists

Contacting the bank, obtaining an extract from the ruling

The simplest way is to contact a bank branch or use internet banking to request information on arrests on the account. The bank must provide an extract from the enforcement proceedings register with data on the proceeding, date of the ruling, debt amount, and details of the enforcement document.

If the bank refuses to provide information, the client may file a written request with the NBU demanding reasons for the refusal as prescribed by law.

Through the ERDR/Diia, apps

To obtain information electronically, you can use the Ministry of Justice online services to check enforcement proceedings and related restrictions by the enforcement document number. Some banks also display arrest details directly in their apps (proceeding number, enforcement officer, and the basis for restrictions).

Some banks have integrated such services directly into their mobile apps, enabling checks for arrests in a few clicks without using third-party resources.

Partial access to funds

Up to 2 minimum wages (16,000 UAH) per month — new rules from 06.05.2023

During martial law, a Cabinet resolution entitles individuals to withdraw up to two minimum wages. As of July 2025, this is 16,000 UAH per month. The limit refreshes automatically each month without the need to re-apply to the bank, greatly speeding access to funds even where several arrests are in place across different accounts. This rule applies to all arrested accounts, regardless of the number of enforcement proceedings. If the account balance is less than the limit, the bank, upon the client’s request, releases the entire available amount.

A client may submit a monthly request, but modern banking systems have automated the process to allow receipt of funds without reapplying. This reduces the administrative burden and speeds access to money.

Protected social payments (pensions, salaries)

Certain social payments and funds may be protected from enforcement. In practice, the bank may request confirmation of the payment type, and the enforcement officer must lift the arrest from funds that are exempt from recovery under the law.

Additionally, during wartime the government may introduce temporary support programs — for example, payments to IDPs or compensation for lost property — which are also protected from arrest.

Full lifting of an arrest

Full repayment of debt — automatic

To fully lift an arrest, the debt must be repaid in full. Once funds are received, the enforcement officer issues a ruling to terminate enforcement, and the bank removes restrictions within one business day.

Be sure to keep all payment confirmations and submit them to the enforcement officer within the prescribed time to avoid delays.

Application to the enforcement officer / settlement agreement

If you cannot pay the full amount, you may initiate a settlement agreement with the creditor. The agreement sets a repayment schedule and terms, after which the enforcement officer issues a ruling changing the method of enforcement or lifting the arrest. This can unblock the account before the main obligation is fully discharged.

In some cases, the creditor may agree to installments secured by collateral or a third-party guarantee, which can greatly facilitate negotiations.

Court appeal — against a notarial writ or groundless decision

If a notarial writ was used or the enforcement officer’s ruling is erroneous, you can bring a court action to declare the officer’s actions unlawful and cancel the ruling. Courts often uphold such claims where they find missed deadlines, lack of legal grounds, or document defects.

When preparing a claim, it is advisable to involve a credit/loan attorney specializing in enforcement proceedings to minimize the risk of dismissal due to procedural errors.

Procedure for lifting an arrest

Identify the grounds, obtain the ruling

The first step is to contact the bank for a copy of the enforcement officer’s ruling. The document must indicate the proceeding’s details, date, and basis for the arrest.

It is also useful to check whether multiple proceedings target the same account to avoid misinterpreting the debt amount.

File an application with the enforcement officer/bank

After reviewing the ruling, prepare an application to the enforcement officer to change the method of enforcement or to terminate the proceeding (if the debt is paid). In parallel, send the bank a copy of the application and the officer’s ruling with a request to lift the arrest within the statutory limits or in full.

Your application should include the exact account details, method of receiving a response, and the desired date of lifting the arrest.

Obtain the ruling and submit it to the bank

Once the enforcement officer grants your application, they issue a new ruling. Submit it to the bank in paper or electronic form (depending on the bank’s policy). The bank lifts the arrest within one business day after receiving the ruling.

After the arrest is lifted, the client may request the return of erroneously withheld funds by filing a claim with the bank.

Case law

Arresting “accounts” instead of “funds” — a legal error that does not always lead to cancellation

Courts — including in enforcement or criminal proceedings — quite often misuse terminology: they impose an arrest on accounts rather than on funds as required by law; or, conversely, they cancel an arrest on accounts instead of funds. Formally, such a legal error is not, by itself, sufficient to automatically cancel an arrest, as repeatedly emphasized by the Supreme Court.

“The panel rejects the applicant’s arguments regarding the unfounded obligation of the chief state enforcement officer to lift the arrest not from the debtor’s funds but from their accounts, since in the absence of funds in such accounts that are subject to compulsory recovery, maintaining an arrest on the accounts as a whole is impractical and violates the debtor’s right to remuneration for work and the right to social protection” (para. 77).

“Moreover, the Supreme Court has repeatedly allowed the possibility of lifting an arrest specifically from the debtor’s accounts” (para. 79).

Examples of mistakenly imposed arrests

In February 2024, a regional enforcement office mistakenly arrested an employee’s salary account; the person had ATO veteran status. The court panel found the ruling was issued without checking the veterans’ register, fully lifted the arrest, and the bank restored access to funds.

Another case concerned an entrepreneur whose corporate account was arrested due to erroneous inclusion in the tax debtors’ register — the court found a violation and awarded moral damages.

FAQ

How to check for an arrest?

Contact any bank branch for an extract from the enforcement proceedings register or use the ERDR web portal or the Diia service. Additionally, you can check the proceeding’s status by calling the enforcement service.

How much can be withdrawn?

During martial law — up to two minimum wages (16,000 UAH) per month, plus social payments (pensions, benefits, salaries of public-sector employees) without restrictions. The limit refreshes automatically each month.

What if the bank won’t unblock?

File a complaint with the National Bank of Ukraine via the hotline 0 800 505 240 or the online form at bank.gov.ua, and also contact the enforcement officer requesting a reasoned refusal. You can also challenge the actions through the NBU complaint procedure and/or in court, depending on the circumstances.

How to appeal?

File a claim with the local court to declare the enforcement officer’s ruling unlawful and to lift the arrest, substantiating procedural violations. If needed, you can involve an attorney or an NGO for free legal aid.

Legal assistance

Pravovyi Lider provides end-to-end support in lifting arrests: from analyzing rulings to representation in court and before the enforcement service. Our experts will craft a strategy, conclude settlement agreements, prepare complaints, and ensure swift restoration of financial access.

We also offer free consultations for citizens affected by unlawful arrests during martial law.