The determination by the International Monetary Fund (IMF) on the status of Ukraine's debt to Russia worth $3 billion – either commercial or official - may affect future disbursements under the Extended Fund Facility Arrangement (EFF) for Ukraine, according to a memorandum on the exchange of securities which has been posted on the website of the organizer of the deal, D.F.King.

According to the memo, the current policy of the IMF is that it may not extend financing to a member which has arrears under official debt.

"Although Ukraine is treating the December 2015 notes on the same basis as all its other sovereign eurobonds for the purposes of the invitation, to date the IMF has not determined whether the December 2015 notes have the status of commercial or official debt under their internal methodology," reads the memo.

"Should the December 2015 notes be treated by the IMF as official debt, and should Ukraine fall into arrears on payments due under the December 2015 notes, then in the absence of a change in policy the IMF may be unable to continue making disbursements to Ukraine under the 2015 EFF. Any such failure by the IMF to make future disbursements under the 2015 EFF could also affect the ability of other international partners of Ukraine to provide financing for Ukraine," the memo said.

"In the absence of access to the international financial markets, such loss of financing from the IMF and other international partners could have a material adverse impact on the financial position and liquidity of Ukraine and on its ability to service its obligations under the new notes and the GDP-linked securities," the memo said.

During her visit to Kyiv on September 6, IMF Managing Director Christine Lagarde said that Ukraine has implemented the latest payments on "Russian" eurobonds in June, therefore the country currently has no any debts to Russia.

However, the terms and conditions of the December 2015 notes contain a covenant relating to the ratio of state debt to GDP that is not included in any of the other eurobonds issued by Ukraine in the international capital markets.

"It is possible that under certain interpretations of that covenant at a certain point in time the increased incurrence of debt, the fluctuations in foreign exchange rates or the deterioration of the Ukrainian economy or a combination of all three could lead to a breach of this covenant, potentially giving the holders of the December 2015 notes (understood to be under the control of the Russian government) the right to accelerate them and thereby trigger cross acceleration provisions in Ukraine's other outstanding eurobonds and other debt stock," the memo said.