Ukraine's largest financial institutions to reduce transfer limits: which banks have already joined

A memorandum on ensuring the transparency of the payment services market has been signed.

This is stated in a joint press release of the participants, the Ministry of Finance reports with reference to the text of the Memorandum.

The signatories of the memorandum are Volodymyr Mudryi, Chairman of the Board of the Independent Association of Banks of Ukraine, Andriy Dubas, President of the Association of Ukrainian Banks, Serhiy Naumov, Chairman of the Board of Oschadbank, Natalia Gurina, Deputy Chairman of the Board of Raiffeisen Bank, Yevhen Zaigraiev, Member of the Board of PrivatBank, and Iryna Starominska, Chairman of the Board of Universal Bank.

According to Ekonomichna Pravda, the memorandum was signed by PrivatBank, Oschadbank, OTP Bank, Pravex Bank, FUIB, Raiffeisen Bank, Universal Bank (Monobank) and Tascombank.

The memorandum concerns the interaction of banks and payment service providers with individual clients, individual entrepreneurs and sole proprietors as part of a group of related companies, improves and standardizes banks' approaches to monitoring client transactions using a risk-based approach, which will help eliminate options for unfair competition, the Ministry of Finance writes. This is an initiative of the banking sector aimed at reducing the shadow economy, as well as countering Russia's terrorist and sabotage activities.

The payment service providers that have joined the Memorandum agree to implement unified market practices and approaches in their activities. In particular, to the following processes

• due diligence of customers at the stage of establishing business relations;
• monitoring of financial transactions on customer accounts in accordance with the available information about the customer and the actual transactions;
• establishing automated round-the-clock rules for monitoring payment transactions, with a special focus on monitoring and restricting transactions at night (from 24:00 to 06:00), to identify cases of unusual financial behavior and to counteract fraudulent schemes, theft of funds through social engineering, and preventing customers from participating in drug schemes;
• establishing rules for conducting financial transactions (providing products or services) of customers in accordance with agreed approaches and procedures based on a risk-based approach;
• exchange of information between the banks participating in the Memorandum on customers and their activities that contain signs of suspicion in accordance with the requirements of applicable law and NBU regulations.

This will mean that banks will not set limits on transactions of customers with verified sources of income (including salary customers and other customers with verified income), as well as volunteers identified by the payment service provider in accordance with the requirements of the law.

If there is no documented income, banks are obliged to set limits (applicable to transfers to IBAN details) on transactions from February 1, 25:

• for high-risk customers, set a limit of up to UAH 50 thousand per month;
• for medium and low risk customers - in accordance with the limits and terms of phased implementation:
  from 01.02.25 in the amount of up to UAH 150 thousand per month;
  from 01.06.25 in the amount of up to UAH 100 thousand per month.

The limits will not include transactions for transferring funds between two accounts opened by the client in the same bank. If the client has documented income exceeding the limit set as of the date, banks will make transfers within the limits of the confirmed income.

In addition, during the service, the client has the right to apply to the payment service provider with a request to increase the established limit with the obligatory provision of documentary evidence of funds.

It is worth noting that Andriy Pyshnyi, Governor of the National Bank of Ukraine , denied that the NBU threatened bankers who did not sign the memorandum on reducing the transfer limits.

Ігор Льов