You do this more than three times a month: why banks may block accounts or transfers of Ukrainians

In Ukraine, banks are obliged to conduct financial monitoring of their clients and stop transactions that they consider suspicious (risky). The requirements are increasing, and in some cases, the bank may consider not only a specific transaction but also cooperation with the client in general to be risky. In this case, accounts will be closed even without explanation.

At the same time, the NBU's Guidelines on signs of risky transactions all banks adhere to are in effect, OBOZ.UA says. If a bank considers a transaction to be risky, it may suspend it and ask for documents to confirm the legality of the transaction. These are the following cases:

• regular (more than 3 times a month) cash withdrawals from the client's account(s); for work that does not provide for a salary higher than the average salary in the relevant region of Ukraine;
• delegated their rights to open and/or manage the account(s) (except for term deposit accounts) to a third party;
• opened an account, conducted (or attempted to conduct) a financial transaction using a lost passport (or other identity document);
• carried out financial transactions with cash in amounts that:

- do not correspond to the available information on the financial condition of the client;

- correspond to the available information on the client's financial condition, but the frequency of conducting (daily or several times during the week) and significant amounts of such transactions may indicate that the individual's accounts are being used for other purposes;

• regular (more than 3 times a month) receipt of funds (including from abroad), which are subsequently withdrawn in cash;
• regular (more than 3 times a month) receipt of cash as a loan from the bank, which is repaid on the same day or within the next few days, in particular at the expense of funds received by the client's account in non-cash form.

Other transactions performed by bank customers that may indicate risks of legalization (laundering) of the proceeds of crime may also be considered risky,

There is a separate group of reasons for financial monitoring - threshold amounts after which the provision of documents confirming the origin of funds is mandatory. We are talking about UAH 400 thousand. If it is a smaller amount, banks use a risk-based approach. All atypical transactions, including cash, cryptocurrency, casino winnings, and transfers from the State Register of National Public Figures (public figures, officials, government representatives), etc. are considered risky.

Article 15 of the law regulating financial monitoring sets forth the following reasons for termination of the agreement at the initiative of the bank:

• if it is impossible to identify and/or verify the client;
• if the client is identified as having an unacceptably high risk or fails to provide the documents or information necessary for proper verification;
• submission of false information by the client or their representative or submission of information with the intent to mislead;
• if it is impossible to identify the person on whose behalf or in whose interests the financial transaction is carried out.

As reported, for his part, economist and executive director of the Economic Discussion Club Oleh Pendzyn said that by the end of 2025, the dollar exchange rate in Ukraine could reach UAH 47.5.

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