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P2P Arbitrage in Ukraine: monobank, Transfer Limits and Crypto Taxes

Everything about P2P arbitrage with the hryvnia: which exchanges and banks work now, where the card-to-card transfer limits came from, how banks react to P2P trades, how much tax you pay on crypto income today and what will change once the virtual assets law is passed.

Published12 min read
Two plain bank cards next to a smartphone with transfer waves, a brass padlock, gold coins and a stablecoin token on a pedestal inside a glowing limit ring — cover of the Ukraine P2P arbitrage guide
Illustration: P2P.Army, AI-generated (Leonardo, GPT Image 2).

Exchanges with UAH and the current spread

The hryvnia trades on all nine P2P exchanges P2P.Army tracks; Binance has about 53% of the ads, and the rest is split among Bybit, OKX, WhiteBIT and others. Once the virtual assets law is passed, such exchanges will need authorization from the NSSMC (National Securities and Stock Market Commission). The table below is live.

Live dataUAH on P2P exchanges right now
ExchangeBuy USDTSell USDTSpreadAdsActivity 24H
Binance46.9147.25-0.71%2,241152,480
Bybit47.0348.76-3.55%1,435100,554
Okx47.3648.20-1.73%4413,482
BingX49.3246.88+5.20%2566,471
Gate48.2247.10+2.38%2431,215
Mexc47.2845.77+3.28%23113,354
HTX47.8048.85-2.15%2122,634
Bitget47.9947.05+1.99%2024,538
Kucoin48.8645.69+6.94%103401
P2P.Army data loaded Nov 15, 12:24 PM UTC. Buy is the average of the top ads where merchants sell USDT, sell is where they buy; spread = (buy − sell) / sell.UAH statistics

Average prices mix different payment methods and ads from new accounts, so a large or negative spread in the table is a reason to check, not a trade. Filter counterparties by history in the order book builder.

Payment methods

Live dataTop payment methods for UAH right now
MethodAdsActivity 24HExchanges
Monobank2,86551,2024
Privat Bank (Universal Card)2,64940,4654
PUMB2,13735,8423
A-Bank2,08340,4443
Sense SuperApp8568,1053
Oschadbank74110,0332
Bank Transfer6363,8862
Raiffeisen Bank Aval60411,1041
P2P.Army data loaded Nov 15, 12:24 PM UTC: ads with each payment method across all exchanges.UAH statistics

Card-to-card transfer limits

In June 2024 the NBU (National Bank of Ukraine) sent banks a letter asking them to scrutinize incoming P2P transfers more closely, including small ones at an abnormal frequency — without numeric thresholds. By a resolution of August 27, 2024, the NBU capped outgoing card-to-card transfers at UAH 150,000 per month from October 1, 2024, for six months; after April 1, 2025, this limit was not extended. Since then, limits have been set by a voluntary memorandum of banks:

Transfer limits under the banks’ memorandum
ClientLimit without proof of income
High risk levelUAH 50,000 per month
Low and medium risk level (from June 1, 2025)UAH 100,000 per month
New or “dormant” sole proprietors (FOP) and legal entitiesSeparate limits from August 14 and November 14, 2026 (amendments of May 14, 2026)
Sources: DTKT (May 14, 2026), ForkLog (Aug 27, 2024), LIGA.net, Minfin (Jun 25, 2024). Checked October 30, 2026.

In July 2026 the NBU published a draft resolution on risk levels of payment transactions (for example, more than 10 top-ups in less than an hour); we could not find whether it has been adopted. We have not verified whether monobank and PrivatBank signed the memorandum — check your bank’s terms.

monobank and PrivatBank

In September 2025 monobank support told clients that mass exchanges via P2P may qualify as business activity and asked them to refrain from such operations: the bank may block the card pending a review. In November 2023 PrivatBank said there were no new rules, but the bank may request information when turnover exceeds what was declared; at the same time it cut off a client who had made many P2P trades on Bybit.

Ban on buying crypto from hryvnia accounts

Since April 21, 2022, the NBU has banned buying cryptocurrency from hryvnia accounts — this applies to card payments on exchanges; purchases from foreign currency accounts are allowed within a limit. We found no repeal of this rule. A P2P trade between individuals is technically a card-to-card transfer, so the limits and checks described above apply to it.

Taxes and regulation

Cryptocurrency in Ukraine: rules as of October 30, 2026
RuleWhat it means for a P2P trader
Law 2074-IX “On Virtual Assets” (signed Mar 16, 2022)Not in force: it will take effect only together with amendments to the Tax Code, which have never been passed
Bill 10225-dRegistered Apr 24, 2025, first reading Sep 3, 2025; as of Oct 30, 2026 — “being prepared for the second reading”
Regulator under the billNSSMC (its virtual assets department was created in July 2026); NBU — e-money tokens only
Current taxationPer the STS clarification (Mar 16, 2026): 18% personal income tax + 5% military levy on income received
Military levy5% since December 1, 2024 (Law 4015-IX)
Proposed in 10225-d (not yet in force)23% (18% + 5%) on net annual profit when cashing out to fiat; crypto-to-crypto swaps tax-free; loss carryforward; income up to one minimum wage exempt; P2P without registering as a sole proprietor (FOP) — an annual tax return with exchange statements
Preferential first year (under the bill)5% personal income tax + 5% military levy on the sale amount, with no deduction for costs; the final wording depends on the second reading
Sources: bill 10225-d page (Verkhovna Rada), Rada press service (Sep 4, 2025), Mind (Oct 27, 2026), 7eminar (Sep 8, 2025), YANKIV (Oct 8, 2026), Rates.fm (Mar 30, 2024), Bukhgalter.UA (Mar 16, 2026). Checked October 30, 2026.

The timeline keeps slipping: the second reading was promised for March, then for August 2026. On October 27, 2026, NSSMC head Oleh Semeniuk said the bill would go to its second reading “this month” and called a January 1, 2027 launch unrealistic: after adoption, a transition period of about six months is needed. Keep your trade history — you will need it for your tax return in any scenario.

  1. The law “On Virtual Assets” is signed

    It never took effect.
  2. NBU bans buying crypto from hryvnia accounts

    From foreign currency accounts — within a limit.
  3. NBU limit of UAH 150,000 per month

    On outgoing card-to-card transfers, for six months.
  4. Military levy rises to 5%

    Law 4015-IX.
  5. Limits under the banks’ memorandum

    UAH 50,000 / 100,000 per month without proof of income.
  6. Bill 10225-d passes its first reading

    Crypto taxes and a new version of the law.
  7. First reading of bill 16013 on money mules

    New Article 200-1 of the Criminal Code.
  8. Second reading of 10225-d

    Then a transition period of about six months.

Local risks

The main risk for a USDT seller is receiving money stolen from someone else: the victim goes to the bank and the police, the seller’s card gets blocked, and it is the seller who has to explain where the funds came from. On September 2, 2026, the President submitted bill 16013 on criminal liability for money-mule (“drop”) accounts; on September 15 the Rada passed it in first reading (299 votes). The new Article 200-1 of the Criminal Code provides for a fine of UAH 5,100–17,000 for handing over a card or account access, and for buying, storing or selling such means — a fine of UAH 51,000–170,000 or 2–6 years of imprisonment, up to 8 years for a repeat offense or one committed by a group of persons. We have not confirmed its final adoption.

  • Trade with counterparties who have 100+ orders and a 95%+ completion rate; large amounts with merchants only.
  • Accept money only from the owner of the verified (KYC) account — never from third parties, relatives or “company accounts”.
  • Check the credit in your own banking app, not from a screenshot or an SMS.
  • Keep a separate card for P2P and withdraw profit regularly.
  • For every trade, save the order number, chat, statement, payment reference and the counterparty’s KYC name.
  • Never hand over your card or online banking access to anyone — bill 16013 makes this a criminal offense.
  • If the bank asks you to explain transactions, respond with documents: exchange statements, order numbers and chats.

P2P.Army tools for UAH

To learn the method itself — where the spread comes from, how to assess payment methods, calculate profit and work as a maker in any country — take the free course “P2P Arbitrage from Scratch”.

Frequently asked questions

Is P2P crypto trading legal in Ukraine?

Cryptocurrency is not banned, but there is no dedicated law in force: the 2022 law never took effect, and bill 10225-d is being prepared for the second reading. Banks may restrict cards over mass P2P trades. This is educational material, not legal advice.

What is the tax on crypto income right now?

Per the STS clarification of March 16, 2026: 18% personal income tax and 5% military levy under the general rules. The new rates from bill 10225-d are not yet in force.

What will change once 10225-d is passed?

The bill proposes 23% on net annual profit when cashing out to fiat, no tax on crypto-to-crypto swaps, loss carryforward and a preferential rate in the first year. Exchanges will have to obtain NSSMC authorization. The final wording depends on the second reading.

What are the card-to-card transfer limits?

The NBU limit of UAH 150,000 applied from October 2024 to April 2025. Now the banks’ memorandum applies: without proof of income, UAH 50,000 per month for high-risk clients and UAH 100,000 for others.

Why does my bank block my card after P2P trades?

Banks treat frequent transfers from different people as a sign of a money-mule account or business activity, and they also act on complaints from fraud victims. Accept money only from the counterparty’s account and keep evidence of every trade.

Sources

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    Картка законопроєкту № 10225-д
    Верховна Рада України
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  18. 18.
Tags:#crypto tax#account freeze#payment methods#Ukraine#UAH
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About the author

Antonio Merkle — crypto expert, arbitrage trader and P2P.Army author

Crypto expert, arbitrage trader and investor

Crypto expert and hands-on crypto arbitrage trader, investor and software developer with over 20 years of experience. On the P2P.Army blog he covers exchange news, P2P and cross-exchange arbitrage.

  • Crypto arbitrage
  • P2P arbitrage
  • Cross-exchange arbitrage
  • Crypto exchanges
  • Investing
  • Software development
All articles by the author →
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