From January 1, 2025, new requirements for financial monitoring will come into effect in Ukraine, which will significantly change the rules of banks' work with individuals and individual entrepreneurs (PPOs). According to the Memorandum approved by the National Bank, restrictions on the number of accounts and limits on money transfers are introduced.
This is stated in the draft Memorandum prepared by the banks, the signing of which may begin this week and extend indefinitely. It is expected that large banks will join it first, and then smaller structures.
Fragmentary data about this document arrived in mid-November, and "Strana" wrote about it a few weeks ago. At that time, it was known about the intentions of the banks to establish enhanced control over the operations of Ukrainians from 50,000. hryvnias, if they were preceded by a cash deposit.
And from the latest edition of the Memorandum, it became clear that not only money transactions after cashing in, but all without exception, will be under increased control.
The document outlines four key directions. First, at the stage of opening an account for a person or an FOP, a new client must be assigned one of three risk categories. Low and medium risk - in this case, the bank applies simplified verification measures: without mandatory confirmation of income, that is, the bank does not ask to provide a salary certificate or tax declaration, if it is a FOP. This category should include clients who, during the initial questionnaire, declare a monthly income of up to 150 thousand. UAH - from January 1, 2025 up to 100,000 UAH - from June 1, 2025.
High risk may be assigned to customers with large amounts of income, or who are PEPs (politically significant persons), or if their suspicious transactions in other banks are known, etc. Such people will be asked for more supporting documents, and their transactions will be heavily scrutinized as part of financial monitoring.
The second direction of the Memorandum is the monitoring of payment transactions. Here, additional restrictions are introduced for clients depending on the assigned risk category (low, medium, high). In the absence of documented income - that is, without providing the bank with certificates, declarations - financiers introduce their own restrictions on any money transfers (an exception will be made for volunteers, owners of salary cards):
1. A limit of 50,000 is set for high-risk clients. UAH per month.
2. Medium and low risk clients have two changing limits:
- up to 150 thousand UAH - from January 1, 2025;
- up to 100 thousand UAH - from June 1, 2025.
These limits can be reviewed individually for each person after providing income documents, depending on their size in each case.
We will remind that from October 1, 2024, the National Bank introduced a ban for all individuals on p2p money transfers (using bank card numbers) over 150,000. UAH/month with a few exceptions. For example, the limit does not apply to IBAN transfers (by account numbers). But the above restrictions within the Memorandum have no exceptions and apply to all transfers: both p2p and IBAN.
The third direction involves the introduction of a ban on opening more than 3 current accounts in the same currency for clients without officially confirmed income. An exception is for credit, deposit accounts and accounts under government programs (for example, National Cashback, eRenovation).
The fourth direction of the Memorandum concerns the creation of a centralized register of questionable clients, whom financiers call "financial mules" - the National Bank called them drops (people who give their accounts to third parties for a fee). Banks that have signed this document are going to share customer information. So, if a person is forced to close an account in one bank, he will have problems opening it in other financial institutions.
