FUIB respects the decisions of the National Bank of Ukraine and prioritizes compliance with financial monitoring legislation.
The bank has taken into account the NBU’s comments to further improve and fine-tune its processes and procedures to meet the requirements of financial monitoring legislation. At the same time, the identified violations are not systemic and do not indicate a lack of an adequate risk management system or proper organization and conduct of initial financial monitoring at PUMB.
To date, PUMB has already developed an action plan to address the identified shortcomings and further improve internal procedures and controls in the area of financial monitoring. The bank systematically invests in the development of technological solutions and process automation aimed at enhancing the effectiveness of its financial monitoring system.
FUIB continues to engage constructively with the National Bank of Ukraine and is consistently working to improve the effectiveness of its financial monitoring system.
It should be noted that FUIB is one of the largest taxpayers in Ukraine. Since 2022, the bank has paid 20.4 billion UAH in taxes to budgets at all levels. At the same time, PUMB actively supports Ukraine and its defense forces: the bank’s investments in social projects since 2022 have exceeded 1.4 billion UAH, of which more than 544 million UAH has been allocated to support the Armed Forces of Ukraine, the Territorial Defense Forces, the State Emergency Service, the National Police, the National Guard, the Main Intelligence Directorate, and the Security Service of Ukraine.
In June 2026, the National Bank of Ukraine fined JSC “PUMB” 10 million hryvnia for violating financial monitoring regulations, the regulator announced on July 7.
According to the NBU, the violations involved inadequate verification of new and existing customers, as well as a failure to apply enhanced due diligence measures to customers with high-risk business relationships.
The regulator also pointed out the bank’s improper application of a risk-based approach. In particular, the NBU noted that the bank failed to identify a high level of risk in business relationships with clients whose ultimate beneficial owners are citizens of a state engaged in armed aggression against Ukraine.
Furthermore, according to the NBU, the bank failed to promptly notify the specially authorized body of threshold financial transactions and violated requirements regarding the termination of business relationships with clients who did not provide documents or information necessary for proper verification.
In addition to the fine, PUMB received a written warning for deficiencies in its internal financial monitoring documents. The NBU noted that these documents lacked procedures sufficient for effective risk management and for preventing the use of banking services for money laundering, terrorist financing, or the proliferation of weapons of mass destruction.
FUIB—First Ukrainian International Bank—is one of the largest private banks with Ukrainian capital. The bank has been operating since 1991 and provides services to private clients, entrepreneurs, and businesses. FUIB is classified as a systemically important bank by the NBU and serves approximately 147,000 corporate clients and 1.9 million retail clients.
According to “Serbian Economist,” the Financial Action Task Force (FATF) has added Bosnia and Herzegovina to the list of jurisdictions under enhanced monitoring—the so-called “gray list.”
At the same time, Iraq was also added to the “gray list.”
According to the FATF, countries on the “gray list” have strategic deficiencies in their systems for combating money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, but are committed to addressing these issues within agreed-upon timeframes.
FATF President Elisu de Anda Madrazo stated that Bosnia and Herzegovina must strengthen the protection of its financial system against exploitation by criminals and terrorists, as well as ensure more effective oversight of the banking sector.
This is a significant signal for the region. Bosnia and Herzegovina remains part of the Western Balkan economic space, closely linked to Serbia, Croatia, Montenegro, and EU countries through banking, trade, remittances from the diaspora, transportation, construction, and small businesses.
Being placed on the “gray list” does not imply sanctions or a ban on transactions, but it typically leads to stricter compliance requirements on the part of banks and financial institutions. International payments, opening accounts, servicing companies, transfers, and transactions with counterparties from such a jurisdiction may be subject to additional checks.
This is important for Serbia for two reasons. First, Bosnia and Herzegovina is a neighboring market and a key destination for regional trade. Second, Serbian banks, companies, and exporters working with partners in Bosnia and Herzegovina may face more detailed inquiries regarding the origin of funds, ownership structure, beneficial owners, and the purpose of payments.
From a practical standpoint, businesses working with Bosnia and Herzegovina should prepare transaction documents in advance, verify the authenticity of goods and services, and properly draft contracts and payment justifications. This applies particularly to financial services, trade, real estate, logistics, import-export, and companies with complex ownership structures.
For reference: as of June 19, 2026, the current FATF “gray list” includes Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Côte d’Ivoire, the Democratic Republic of the Congo, Haiti, Iraq, Kenya, Kuwait, Laos, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the British Virgin Islands, and Yemen.
The FATF blacklist—that is, the list of high-risk jurisdictions for which the FATF calls for enhanced measures or countermeasures—includes North Korea, Iran, and Myanmar.
Bosnia and Herzegovina, COMPLIANCE, FATF, financial monitoring, SERBIA
The National Bank of Ukraine fined Avangard Bank JSC 2 million UAH for violating financial monitoring regulations, the regulator announced on its website.
According to the NBU’s statement, the bank was fined for improper application of a risk-based approach, failure to identify a financial transaction subject to financial monitoring, and improper analysis of customer transactions for indicators of suspicious activity.
In addition, the regulator issued written warnings to the bank. These warnings concern the improper development and implementation of internal documents on financial monitoring, as well as the submission of erroneous information on foreign exchange transactions to the NBU.
As previously reported, in May, the NBU imposed sanctions on one bank and nine non-bank financial institutions for violations in the areas of financial monitoring and foreign exchange legislation.
Bank Avangard JSC operates in the Ukrainian banking market and provides services to corporate and private clients.
In May 2026, the National Bank of Ukraine (NBU) fined LLC “1 Safe Agency of Necessary Loans” (TM “MyCredit”) 6.13 million UAH and Avangard Bank 2 million UAH for violating financial monitoring regulations, the regulator announced on its website.
According to the statement, LLC “1 Safe Agency of Necessary Loans” was fined for improper organization and conduct of initial financial monitoring. In particular, the National Bank pointed to violations in the application of a risk-based approach, the development of internal documents, proper customer due diligence, work with politically exposed persons, and the provision of information in response to the regulator’s requests.
Avangard Bank was fined for improper application of a risk-based approach, failure to identify a financial transaction subject to financial monitoring, and improper analysis of customer transactions for indicators of suspicious activity.
In addition, the financial institution received written warnings for the improper development and implementation of internal documents on financial monitoring, as well as for submitting information on foreign exchange transactions to the NBU with errors.
The Central Bank also fined FC “A Finance” LLC 800,000 UAH for violating the procedure for conducting currency exchange transactions and failing to equip a separate structural unit with a video surveillance system.
FC “MBK” LLC was fined UAH 799,000 for violating financial monitoring requirements, specifically the improper submission of information and documents in response to requests from the National Bank, failure to fulfill the obligation to conduct proper customer due diligence, improper application of a risk-based approach, violation of the procedure for storing documents in client files and preparing statistical reports on AML/CFT issues.
The company also received a written warning for improper development and implementation of internal documents on financial monitoring, deficiencies in the operation of the automation system for continuous monitoring of client transactions, and failure to include verified information in client questionnaires.
PT “Pawnshop No. 1” of “Contract-Group” LLC was fined 200,000 UAH for violating the procedure for conducting foreign exchange transactions, specifically the cashier’s failure to provide cash register receipts simultaneously with the receipt or issuance of cash in foreign currency for reversal and verification transactions.
In addition, the pawnshop received a written warning for the absence in a separate structural unit of a copy or excerpt from the order on its opening, specifying the list of transactions carried out at the cash desk, as well as for violating the requirements for technological video surveillance systems.
Alliance Capital Group FC LLC was fined UAH 100,000 for violating the procedure for conducting currency exchange transactions, specifically the cashier’s failure to accept or issue cash for a currency exchange transaction simultaneously with the issuance of a cash register settlement document.
The regulator also issued a written warning to the company for violating the requirements for the video surveillance system, specifically the absence of date and time information in the video footage from the customer area.
FC “Alfa-Invest Group” LLC received a written warning for violating the procedure for conducting currency exchange transactions, which consisted of failing to issue foreign currency cash to an individual customer simultaneously with the provision of a cash register receipt.
As reported, in May, the NBU fined LLC “FC ”Kontraktovy Dom“ and LLC ”Swift Garant” 135.15 million UAH each for improper organization and conduct of initial financial monitoring. In addition, PJSC “Insurance Company ”VUSO” was fined UAH 40.71 million for a similar violation.
Financial monitoring is transforming from a formal regulatory obligation into a full-fledged business function, and manual AML processes create operational and reputational risks for companies, while automation allows embedding risk management into the digital business architecture, according to Oksana Gubina, CEO of AML.point.
According to her assessment, the growth in transaction volumes, increasing complexity of financial products and strengthening regulatory requirements increase the risks of using fragmented systems and so-called “Excel-AML”, increasing dependence on the human factor and the likelihood of errors.
Gubina notes that automation in AML should not mean speeding up individual checks, but rather integrating financial monitoring into core systems and building a unified customer profile that allows a shift to proactive, data-driven risk management.
She also pointed to a shift from a product-centric to a client-centric approach in AML, as risk is linked to the profile and behavior of a client who may be using multiple products at the same time.
According to the author, customer-centric financial monitoring is scheduled to be discussed in more detail on February 18, 2026 at IFC Bankir’s Banking Forum: DIGITAL TRENDS 2026 conference, where she will be a speaker.
https://interfax.com.ua/news/blog/1142350.html
