For more details about the changes in banking operation rules, visit RBK-Ukraine. This information is reported by Kontrakty.UA.
Why Banks Are Introducing Restrictions
In December 2024, several major Ukrainian banks and associations signed a Memorandum to ensure transparency in the payment services market.
The document outlines the introduction of limits on money transfers, classification of clients by risk groups, checks for individual entrepreneurs, and more. However, these new measures will only apply to those bank service users who cannot verify the legality of their income.
The National Bank of Ukraine (NBU) and the signatories of the Memorandum explain that the goal of this initiative is to:
- reduce the shadow economy;
- combat fraudulent financial schemes, particularly the use of "drops" (clients who provide access to their cards or accounts for dubious transactions in exchange for a fee);
- align the Ukrainian banking sector with unified standards and requirements of EU legislation.
As of January 27, 2025, the Memorandum has been joined by 44 banks and 2 payment systems (Oschadbank, PrivatBank, Raiffeisen Bank, PUMB, Universal Bank, Sens Bank, payment systems NovaPay, RozetkaPay, and others).
Limits Starting February 1: Which Transfers, Amounts, and Other Innovations
Since October of last year, a limit set by the NBU on money transfers between individuals from card to card (P2P) has been established at 150,000 UAH per month for Ukrainians.
According to the Memorandum, starting February 1, 2025, restrictions will not only apply to P2P transfers but also to outgoing transfers using IBAN details in both national and foreign currencies.
These measures will be implemented for clients without verified income, depending on which risk group they belong to:
- clients in the "high" risk group - a limit of 50,000 UAH per month;
- clients in the "medium" and "low" risk groups - a limit of 150,000 UAH per month (reduced to 100,000 UAH starting June 1).
However, the Memorandum does not define the degree of "riskiness." Each bank will apply its own assessment criteria when opening an account and during further client servicing.
At the same time, the document states that enhanced verification measures must be applied for clients in the "high" risk group in each specific case. Clients in the "low" and "medium" risk groups will undergo a simplified verification process.
Banks will also impose restrictions on the number of accounts (credit, deposit, and accounts for state program payments are not counted). A client without verified income sources may have no more than 3 accounts in one currency.
Financial institutions will conduct in-depth studies of the business activities of newly established individual entrepreneurs (up to 6 months) in the first taxation group and will monitor account transactions according to the average monthly income amount. Individual entrepreneurs in the general or simplified taxation systems of the 2nd and 3rd groups will be assessed according to their own risk-oriented criteria.
Banks will carry out round-the-clock monitoring of payment operations with particular attention to transactions during nighttime (from 12:00 AM to 6:00 AM) to identify cases of atypical financial behavior and combat fraudulent schemes.
Who Will Not Be Subject to Limits
The restrictions on transfers will not affect bank clients with verified incomes (salary clients and others), as well as volunteers whose activities are documented (according to NBU Resolution No. 18 dated 02.24.2022 "On the Operation of the Banking System During Martial Law").
Limits will not apply to transactions transferring funds between two accounts opened by the client in one bank.
As explained by NBU head Andriy Pyshny, banking restrictions will affect no more than 1% of the client base. This exclusively includes those clients who have not provided documentary evidence of their income, particularly those classified as "high-risk."
"If you are working 'legally', receiving a 'white' salary, or can otherwise document your income or assets, nothing will change for you at all. Just as it did not change for you in October 2024 when the NBU took the first step to address the issue of drops by establishing a general framework for all clients", noted Pyshny.
The head of the National Bank added that the successful implementation of the Memorandum could pave the way for the early lifting of the temporary limit on P2P transfers, which was introduced in October 2024 for six months.
Documents for Income Verification
The innovations starting February 1 do not require updating income information for bank clients.
"The Memorandum does not contain any requirements for additional identification, as this has already taken place during the account opening process", explained Andriy Pyshny.
However, if a client wishes to conduct a transaction exceeding the established limit, they must provide documentary proof of the source of the funds.
This may include electronically generated certificates OK5 and OK7, tax declarations, payroll records, confirmations of deposits from government agencies, verified income of family members, and documentation of volunteer activities.
The preparation of this material utilized: the text of the Memorandum on ensuring the transparency of the payment services market, publications from the Association of Ukrainian Banks, and a post by NBU head Andriy Pyshny on Facebook.