1. Why the Rules Changed
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June 2025 launch — The National Bank of Ukraine (NBU) rolled out stronger AML/CTF (anti–money-laundering / counter-terrorist-financing) requirements for all banks and payment-service providers.
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Goal: Spot anomalous payment behaviour early, block illicit flows, and standardise monitoring algorithms across the sector.
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Next step: The NBU is drafting unified guidelines so every bank “understands where it needs to move,” the regulator says.
2. Who Is Likely to Face Extra Checks
| Trigger | Typical Examples |
|---|---|
| Large crypto deals | One-off buy/sell operations of significant value |
| Unusual high-value transfers | Sudden receipt or outgoing of six-figure hryvnia sums |
| Cross-border inflows | Regular payments from foreign counterparties |
| Near-limit activity | Total monthly P2P transfers edging toward ₴100 000 ceiling |
| Patterned payments | Many identical transfers to third-party accounts (e.g., “envelope salaries”) |
The bank’s internal scoring engines flag these events for manual review.
3. What Happens During a Review
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Document request – The bank contacts the client via app, email or phone.
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Temporary freeze – Access to some or all functions may be paused until paperwork arrives.
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Verification – The compliance team inspects the source-of-funds evidence.
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Outcome
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Approved: account unblocked; limits may even rise if income exceeds ₴100 000/month.
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Unresolved: transactions remain suspended and can be reported to the State Financial Monitoring Service.
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4. Acceptable Proof of Income
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Notarised sale-and-purchase agreements (real estate, vehicles, etc.)
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Personal income tax or sole-proprietor (FOP) declarations
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Bookkeeping statements or payroll certificates
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Loan or repayable financial-assistance contracts
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Cashier receipts confirming large cash deposits
Tip: keep digital copies ready; banks now process most checks online.
5. Looking Ahead – Toward “Smarter” Monitoring
The NBU wants advanced behavioural-analytics systems to replace blanket limits. Once fully deployed, genuine customers should experience fewer blockages, while illicit flows become easier to spot.
“With mature anomaly-detection tools, basic restrictions will lose relevance,”
— NBU statement
