Regarding cooperation Ukraine - Russia

Accountor Kyiv would like to thank you for the long and mutually beneficial cooperation. We hope that you and your employees are safe. We would also like to inform you about the following.

In connection with Russia's military aggression against Ukraine, on March 4, 2022, the Resolution of the Cabinet of Ministers # 187 of March 3, 2022, entered into force – namely, "On ensuring protection of national interests in future lawsuits of Ukraine in connection with military aggression of the Russian Federation" (hereinafter referred to as the “Resolution”).

Clause 1 of the Resolution establishes a moratorium on:

1) performance, including compulsorily, of payment obligations and other obligations if the creditors (collectors) is/are the Russian Federation or such entities as (hereinafter – “entities associated with the aggressor state”):

a) citizens of the Russian Federation;

b) legal entities established and incorporated in accordance with the laws of the Russian Federation;

c) legal entities established and incorporated in accordance with the laws of Ukraine, whose ultimate beneficial owner, member or participant (shareholder) with a share in the authorized capital of 10 percent or more, is the Russian Federation, a citizen of the Russian Federation or a legal entity established and incorporated in accordance with laws of the Russian Federation.

This restriction does not apply to citizens of the Russian Federation residing in Ukraine legally and legal entities established and incorporated in accordance with the laws of Ukraine whose ultimate beneficial owner, member or participant (shareholder) is/are exclusively citizens of the Russian Federation legally residing in Ukraine, or exclusively citizens of Ukraine and citizens of the Russian Federation legally residing in Ukraine;

2) alienation, pledge, any other action which results or may result in the alienation of immovable property, securities, corporate rights, vehicles, aircraft and ships, inland waterway vessels by entities associated with the aggressor state, with the exception of gratuitous alienation in favor of the state of Ukraine;

3) alienation, pledge, any other action which results or may result in the alienation of immovable property, securities, corporate rights, vehicles, aircraft and ships, inland waterway vessels for the benefit of persons associated with the aggressor state, or in favor of the Russian Federation

Thus, the Resolution establishes that the concluding any agreements or voluntarily making settlements under any agreements, under which residents of Ukraine have payment obligations, is considered null and void.

Transactions and documents (including powers of attorney) concluded in violation of the moratorium specified in clause 1 of the Resolution, including the ones providing for such alienation in the future, are also considered null and void.

  In addition, according to the Law of Ukraine "On Prevention and Counteraction to Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction", any financial transactions suspected of terrorism financing is to be checked and reviewed.

Thus, funds related to the fulfillment of payment obligations (under any agreements) received by entities specified in clause 1 of the Resolution may be used to finance military aggression and terrorist acts by the Russian Federation in Ukraine and are subject to financial monitoring.

To minimize possible risks of the above consequences, Accountor Kyiv recommends:

1.  Do not enter into agreements with entities specified in clause 1 of the Resolution, under which your Company shall have payment obligations or other obligations to such entities, as well as into agreements, the subject of which shall be the property specified in clauses 2, 3 of the Resolution.

2. Do not perform payment obligations or other obligations under existing agreements (oral or written ones), as well as under agreements the subject of which is the property specified in clauses 2, 3 of the Resolution, in favor of the entities specified in clause 1 of the Resolution.

As a company subject to primary financial monitoring, Accountor Kyiv has the right to suspend payments violating the requirements of the Resolution.

If you have any questions, please feel free to ask.

Best Regards,

Executive Director of Accountor Kyiv LLC

Nadiia Kuziv