The National Bank of Ukraine has increased penalties for banks for violating sanctions legislation. Resolution No. 9, which came into force on February 4, provides for an increase in the maximum fine for failure to comply with restrictions on sanctioned persons to 1% of the bank's authorized capital.
Until February 1, the fine was only 0.01% of the bank's authorized capital, but now it has been increased 100 times. For banks with the largest capital, for example, state-owned PrivatBank (UAH 206 billion), this means a possible fine of up to UAH 2.06 billion. For small banks with capital of UAH 200 million, fines can reach UAH 2 million.
The NBU requires banks to deny services and close accounts of individuals on sanctions lists. The regulator has repeatedly noted that banks often delay compliance or make shortcomings in customer due diligence.
One of the biggest challenges for banks is responding quickly to sanctions list updates. The State Financial Monitoring Service regularly updates the list of individuals associated with terrorism or sanctioned activities, and banks must check customers for compliance with this list instantly, even during transactions that take a matter of seconds.
In addition to strengthening sanctions monitoring, Resolution No. 9 provides for new fines for:
- Non-compliance with financial monitoring rules (maximum fine — up to UAH 135.15 million).
- Lack of appropriate equipment in departments for people with disabilities and other low-mobility groups (e.g. ramps, Braille, or appropriate staff).
The NBU requires not only technical compliance with regulations, but also ensuring the accessibility of financial services for all categories of the population.
Financiers acknowledge that the NBU's technical requirements are often difficult to meet in a timely manner, especially given the frequent updates to the sanctions lists. However, the regulator insists that the increased fines are aimed at increasing discipline in the banking sector and ensuring compliance with the law.
The new strict regulation will be a serious challenge for banks, which are forced to adapt to the increased requirements and avoid multi-million-dollar fines.
