Ukrainian Banks Sign Memorandum to Ensure Transparency in Payment Services

Ukrainian Banks Sign Memorandum to Ensure Transparency in Payment Services

On December 10, a significant development in the banking sector took place as the National Bank of Ukraine hosted a press briefing that was marked by the presence of leaders from the Independent Association of Banks of Ukraine (NABU), the Association of Ukrainian Banks (AUB), and major banks such as PrivatBank, Oschadbank, Raiffeisen Bank, Universal Bank, along with representatives from the National Bank of Ukraine. The occasion was dedicated to the signing of the Memorandum on ensuring transparency in the functioning of the payment services market (the Memorandum). This initiative is set to transform the way banks and payment service providers interact with individual clients, sole proprietors, and small enterprises, fostering a more reliable and transparent market environment.

The Memorandum aims at standardizing banks’ procedures for monitoring client transactions through a risk-based approach, significantly reducing unfair competition, and preventing potential financing of terrorist and subversive activities. It underscores a concerted effort within the banking sector to diminish the shadow economy and counteract the misuse of payment infrastructure by nefarious entities, including 'drops', who engage in fraudulent activities.

Moreover, the Memorandum aspires to align the banking industry's practices with the stringent standards and legislative requirements mandated by the European Union. It was collectively developed by NABU and AUB and received backing from the NBU, demonstrating strong inter-organizational collaboration. All banking institutions in Ukraine are encouraged to sign the Memorandum, supporting the principles it advocates.

Key Aspects of the Memorandum

The Memorandum addresses several critical areas:

  • Enhanced due diligence at the initial stage of client interactions.
  • Improved monitoring of financial activities based on actual transactions and client information.
  • Implementation of a 24/7 monitoring mechanism to identify abnormal financial behaviors, particularly focusing on transactions conducted during nighttime.
  • Setting transaction limits based on a client's risk profile and documented income, with specific thresholds outlined for high, medium, and low risk levels effective from February 1, 2025.
  • Encouraging collaboration with the National Bank of Ukraine and other state agencies to access official data (e.g., income information, court cases) and establish a centralized register for dubious clients.

Commitment to Transparency and Security

The Memorandum symbolizes a significant stride towards ensuring a transparent, fair, and secure payment services ecosystem. NBU's Chairman, Andriy Pyshny, expressed gratitude towards the banking community for their self-organization and proactive approach, emphasizing the objective of reducing the shadow economy to fortify the country’s fiscal and security framework.

Leaders from NABU and AUB also reiterated the necessity of uniting efforts to combat fraudulent activities in the financial system, highlighting how the Memorandum represents a collective resolve to address current challenges while maintaining service quality for the majority of users.


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