The problem of some international banks conducting financial transactions for Ukrainian entities operating in the front-line territories has been on the agenda since 2022 due to the difficulties of foreign entities in determining the borders of the temporarily occupied territories of Ukraine.
The Ministry of Reintegration of the Temporarily Occupied Territories of Ukraine with the participation of the National Bank of Ukraine has created an official data source - a landing page on the status of the territories of Ukraine, which can be used by foreign financial institutions https://minre.gov.ua/en/list-of-tot/. The landing page contains a list of temporarily occupied settlements of Ukraine (by regions and districts) in ".xlsx" format, which allows integration into banking systems for further compliance checks. The information on the landing page is updated in real time.
At the same time, we draw you attention to the relevant EU guidance - http://surl.li/nmlbca (Part D. Trade and Customs, paragraph 9 Oblast, p. 190) for financial institutions and business entities.