A client approached AA Lawrange seeking advice on establishing a P2P transaction mechanism through a Ukrainian limited liability company. Well, the idea was quite interesting. It would have allowed him to interact directly with users – no intermediary banks, automated transfers, and maximum efficiency.

 

The client’s inquiry was as follows: is it legally possible to implement such a model in Ukraine? And if not, what alternatives exist that would allow financial operations to be conducted successfully within the law?

 

We took on the project and began our analysis.

 

Want to know more? Details are in the article…

 

P2P via an LLC in Ukraine. Why Doesn’t It Work?

A client, whose name we cannot disclose due to a signed NDA, approached us with a clear business idea: to build a platform for P2P transactions based on a Ukrainian LLC. At first glance, it seems simple, convenient, and modern. However, in practice, such a model contradicts the law from the very beginning.

 

In the current legal system of Ukraine, a legal entity cannot act as an intermediary in P2P operations without violating financial regulations. No permits can change the essence of it: an LLC in Ukraine is not allowed to receive, transfer, or accumulate users’ funds. This is permitted only for banks and other licensed financial institutions.

 

What Did the Lawrange Team Do? Thoroughly, Clearly, and to the Point

To support our conclusion, we conducted an in-depth analysis and provided the client with a well-reasoned response. Here’s how we worked:

 

  1. Studied the client’s business model. First, we decided to understand how exactly the client envisions the process. Who sends the money? Who receives it? What role does the company play in this? How are settlements conducted? This helped us identify the fine line between a simple platform and an activity that requires a financial license.
  2. Checked the current legislation in the P2P field. We reviewed the regulatory framework, NBU clarifications, and laws governing financial services and electronic money. As a result, it became clear: in the format proposed by the client, implementing a P2P platform through a Ukrainian LLC is currently impossible. This scenario contradicts the existing legal norms.
  3. Explained the reasons for the prohibition. We provided the client with detailed clarifications on their inquiry. We explained that an LLC cannot be a provider of payment services without the appropriate license. Moreover, the circulation of electronic funds is strictly regulated by the NBU, and the creation and use of a virtual wallet bypassing banks is not compliant with the law.
  4. Proposed alternatives. The lawyers at AA Lawrange didn’t just say “No.” They offered the client concrete options for achieving their financial goals in a legal manner. These included using banking instruments (including APIs for payment automation), crypto-based models, and partnerships with licensed financial institutions.

 

It is worth noting that the request was quite complex. Therefore, communication took place in several stages. We conducted a series of consultations during which we clarified details, answered follow-up questions, and adapted the solution to real business needs.

 

Result: Honestly, Legally, and with Business Benefit

While working on this project, we (as always) did not look for workarounds or “gray areas” in the legislation. Only legal solutions, clear answers, and realistic alternatives. As a result of the cooperation, our client received:

 

  • A comprehensive legal perspective on their business idea.
  • A clear understanding not only of what is prohibited, but also why exactly it cannot be done.
  • A list of real alternatives that allow progress within the legal framework. 

 

The client appreciated our flexibility, depth, and result-oriented approach. After all, we didn’t just “check the box with a consultation.” We truly helped!

 

Do you also have an idea you want to implement but are unsure about its legality? AA Lawrange will help you see the full picture and build a legal path that takes your goals and possibilities into account. Contact us – we’ll figure it out together!