The National Bank of Ukraine has served banks with Letter No.25-0005/8349, amending the requirements to the comprehensive analysis and verification of information on financial transactions and counterpart to operations involving the purchase of foreign currency to be transferred abroad.
“We maintain a continuous constructive dialogue with banks, the outcome of our discussions is reflected in the decisions taken by the regulator. This being said, the NBU is committed to an approach in which banks are primary subject to financial monitoring as they should “know their customers”, identify and block suspicious transactions,” said Director of the NBU Financial Monitoring Department Mr Ihor Bereza.
From now on, the following financial operations shall not be subject to the verification process:
- transactions under contracts entered into between residents and international companies included in the Forbes Global 2000 list comprising the world’s largest public companies;
- transactions involving settlements between resident economic agents and non-resident economic agents under international agreements;
- transactions to settle liabilities in an amount not exceeding UAH 150,000 per transaction.
Additionally, the regulator has allowed banks to issue one opinion per contract rather than verify each transaction performed under this contract.
One of the key features of a suspicious financial operations shall be the availability of agreements for the delivery of goods and/or services to the customs territory of other countries. As before, the delivery of goods to the customs territory of other countries is an indicator of suspicious financial operations. As prescribed by this Letter, a bank has to verify to verify the validity of documents submitted by the customer and whether they are executed in compliance with applicable Ukrainian laws. If there is a possibility to verify information using public information, including online information, customers are not required to submit additional documents for the verification process.