The National Bank of Ukraine has introduced new, stricter requirements for financial monitoring that will affect both individuals and sole proprietors.
This is reported by Finway
Banks Are Required to Immediately Exchange Information
According to an internal letter from the NBU, which contains recommendations and clarifications regarding financial monitoring, banks and financial institutions must now promptly exchange information about clients whose accounts have been forcibly closed due to violations of monitoring requirements. This rule applies regardless of the establishment of an official centralized registry.
In fact, if a bank closes a client’s account due to suspicion of violating financial control standards and transfers the remaining funds to another institution, it must clearly state the reason for this action. Previously, such explanations were provided only by certain institutions; now this will become a mandatory practice for all banks.
“One of the most noticeable changes is the obligation for banks and financial institutions to exchange information about clients whose accounts have been forcibly closed due to violations of financial monitoring rules. This exchange must occur immediately, without waiting for the launch of any centralized registry.”
As a result, clients who are listed as problematic at one bank may be denied the opening of accounts at other institutions, as their previous experiences will become known throughout the banking system.
“Black List” Without an Official Registry and Increased Attention to Entrepreneurs
The National Bank previously considered creating a centralized database of unreliable clients, known as a “black list,” but this requires legislative changes, and the implementation of such a registry is not expected before the end of 2026. Currently, the regulator is implementing a mechanism for information exchange between banks, which will effectively act as an informal “black list.” Clients deemed risky may be denied access to financial services at most institutions.
Special scrutiny will now apply to sole proprietors. Banks are required to conduct more thorough, regular checks of their activities, not limited to standard questionnaires, but also requesting additional supporting documents. In the case of suspicious transactions, financial institutions must promptly close the accounts of entrepreneurs.
Frequent or significant transfers, especially if made for the benefit of various individuals or legal entities, may attract additional attention from banks. The strictest monitoring will be applied to newly established entrepreneurs who make large transactions immediately after registration—such activity will be considered potentially risky.
Another innovation is the increased transparency for clients. From now on, banks are required to openly communicate the criteria used in financial monitoring and clearly inform clients about which transactions or financial behaviors may lead to restrictions on the use of banking services. Previously, many checks occurred without explanations; now clients will have a fuller understanding of the reasons for the heightened attention to their activities.
Overall, these changes are aimed at combating money laundering; however, increased control may create additional risks for those clients whose financial activities raise suspicions among banks.
