PrivatBank, Oschadbank, Universalbank (mono) and Raiffeisen Bank, which as of October 1 accounted for 64.5% of all household deposits in banks and 87.5% of active payment cards, as well as the National Association of Banks of Ukraine (NABU) and the Association of Ukrainian Banks (AUB) signed a memorandum “On Ensuring Transparency of the Banking Payment Services Market” at the National Bank of Ukraine on Tuesday.
The document envisages the introduction of unified market practices and approaches to due diligence of clients and monitoring of their financial transactions, in particular, it introduces a monthly transaction limit of UAH 50 thousand for high-risk clients without verified income starting February 1, 2025.
For medium- and low-risk customers, the limit is set at UAH 150 thousand per month from February 1 and reduced to UAH 100 thousand from June 1.
This applies not only to card-to-card transfers – P2P transactions, which the National Bank of Ukraine has already limited to UAH 150 thousand per month in one bank – but also to all transactions from current accounts in favor of individuals, including iBAN.
The signatories added that in the case of significant savings or additional confirmed income, limits for customers will be set individually, taking into account the level of income, information about which is planned to be collected automatically from available resources.
In addition, the document establishes approaches to the exchange of banking information and provides for tighter control over the activities of individual entrepreneurs, limits the opening of accounts for customers without verified income to three in the same currency and enhanced control over payments at night.
The signatories of the memorandum ask the NBU to create a centralized register of suspicious customers (drops) in cooperation with the National Bank and provide participants with access to official information through the Diia online service on customer income, court cases, etc.
During the signing, NBU Governor Andriy Pyshnyi expressed hope that other banks and non-bank participants in the payment services market would join the memorandum, while AUB Head Andriy Dubas suggested that the vast majority, and possibly all 61 banks, would sign the document.
NABU Head Volodymyr Mudryi emphasized that this agreement does not violate competition in the market, each bank will continue to set its own tariffs, but it introduces a single barrier to the abuse of the payment system.
“We expect that 9 out of 10 clients will not feel any changes,” said Yevhen Zaigraiev, PrivatBank’s board member for corporate business and SMEs, during the signing.
According to Dubas, only about 1% of clients have “high” risk status.
Pyshnyi noted that if the memorandum is successful, it could replace the relevant regulation of the National Bank, which expires on April 1 next year.
The NBU governor denied information about alleged threats to banks that refuse to sign the memorandum.
The signatories also noted that one of the main goals of the memorandum is to increase state budget revenues.
Mudryi clarified that this memorandum will be valid for the period of martial law or until the introduction of a register of “drops”. According to the National Bank, such a register may be launched in the second quarter of 2026.
As reported, starting from October 1, 2024, the NBU set a limit of UAH 150 thousand per month for outgoing card-to-card (P2P, person-to-person) transfers for six months, although it had previously considered a stricter limit of UAH 100 thousand. “The limit applies only to outgoing transfers on all accounts of the client opened in the same bank to the accounts of other individuals. The limit does not apply to the accounts of volunteers who meet the criteria set out in the resolution and to persons whose monthly income from confirmed sources exceeds the amount of the established limit,” the regulator said in a press release.
It is noted that the limit does not take into account transfers of client funds between their own accounts in the same bank, and it does not apply to transfers of legal entities. Transactions using IBAN details are not limited, the NBU clarified.
The NBU pointed out that 98% of bank customers make monthly transfers that do not exceed this amount.
According to the central bank, the introduced limit will help minimize the use of payment infrastructure in illegal activities, in particular through the use of drop accounts, which are a common mechanism for the shadow economy.
A source in the financial market told Interfax-Ukraine that in the first month of the national banking restrictions, the volume of P2P transactions decreased by UAH 5.2 billion, but at the same time, IBAN transfers increased by UAH 4 billion.
