After record fines imposed by the National Bank of Ukraine on companies operating under the EasyPay and City24 brands, participants in the payment terminal market have begun discussing the introduction of unified enhanced financial monitoring rules.
Among the possible innovations are:
- video verification of clients;
- installation of cameras near terminals;
- time pauses between transactions;
- additional verification of atypical payments.
UNN has analyzed how payments via EasyPay and City24 may change for Ukrainians.
Recently, participants in the payment terminal market have begun discussing the need to introduce common financial monitoring standards.
According to media reports, terminal network operators, together with the Association of Ukrainian Banks, are preparing a memorandum that may establish unified rules for all market participants. The initiative aims to unify approaches to client identification, risk assessment, detection of suspicious transactions, and interaction with the regulator. After the proposals are agreed upon, the document is planned to be submitted for consideration to the National Bank.
What changes may be introduced
One of the most discussed proposals has been video verification of the client at the moment they deposit cash into the terminal. This involves the possibility of installing cameras directly near payment devices or using existing cameras to confirm that the transaction is being carried out by a real person.
Market participants are also discussing the introduction of mandatory time intervals between consecutive payments. Such a mechanism could complicate the mass execution of a large number of transactions over a short period of time.
Among other possible measures that will change the rules for using terminals for people are:
- establishing uniform limits on cash payments;
- additional verification of transactions that are repeated with the same details;
- blocking payments in case of detection of atypical behavior;
- enhanced verification of clients conducting transactions for large amounts;
- detection of payments made in different cities using the same phone number;
- limiting the number of transactions over a certain period;
- expanding the list of data that the client must provide during payment.
At the same time, all these measures are currently at the discussion stage. The National Bank has not yet introduced mandatory requirements for installing cameras or facial recognition. It is also unknown how exactly video recording may be carried out, how long the recordings will be stored, and who will have access to them. These issues will require separate regulation, in particular taking into account legislation on personal data protection.
What has already changed for terminal users in 2026
Certain enhanced requirements for cash transactions via terminals have already come into force.
Thus, from June 26, 2026, when conducting most cash deposit transactions through self-service software and hardware complexes, the user must provide the full mobile phone number. After that, the number must be confirmed using a one-time code from a message or a code received during a phone call.
This requirement does not depend in any way on the amount of cash the client wishes to deposit. Its purpose is to complicate anonymous cash payments and increase the level of traceability of transactions.
However, here too the National Bank of Ukraine has provided a number of exceptions. Additional confirmation of the phone number is not required when paying:
- taxes;
- fees;
- fines;
- administrative services and other payments to the state or local budgets;
- utility services;
- internet;
- television;
- security;
- fixed telephone communication;
- railway tickets;
- urban and suburban transport;
- replenishment of transport cards.
Separate simplifications are provided for mobile phone top-ups within the established limit.
In addition, additional verification may not be applied when topping up one's own card account if the terminal reads the bank card and the user confirms the transaction with a PIN code, a one-time password, or through the bank's mobile application.
How new rules for working with terminals may affect customers
If additional requirements are introduced, processing payments through terminals may take longer. Users will likely have to verify their identity more often, provide additional data, or wait before conducting the next transaction.
For customers who use terminals for one-time household payments, the changes may be almost imperceptible. At the same time, those who regularly deposit large sums or conduct many payments in a row may face additional checks and restrictions.
It is possible that some transactions, if risky signs are detected, will be temporarily suspended until the origin of funds or the purpose of the payment is clarified. Operators may also review limits, payment processing speed, and internal procedures for blocking suspicious transactions.
What possible risks exist for the market
Economists and experts in financial law warn that tightening financial monitoring rules could increase costs for terminal network operators. Companies will have to invest in video cameras, data storage servers, new software, transaction analysis systems, and additional personnel. These costs could potentially affect the amount of fees paid by users.
At the same time, uniform rules may reduce the risk that different operators will apply unequal requirements. Without unified standards, customers or intermediaries may switch to networks with less stringent verification procedures. That is why market participants advocate for equal requirements for all operators, rather than separate restrictions for the largest networks.
Context
In May 2026, the National Bank applied fines in the amount of UAH 135.15 million to each of the following companies: LLC "FC "Kontraktovyi Dim"", which operates under the EasyPay brand, and LLC "Swift Garant", which represents the City24 network.
The total amount of sanctions was UAH 270.3 million. These are among the largest fines the regulator has applied to non-bank financial institutions for violating requirements in the field of financial monitoring. The NBU published information about this on June 5. At the same time, the decisions themselves were adopted back in May 2026.
What were the NBU's claims
The National Bank stated that during inspections it found violations of legislation in the field of preventing and countering the legalization of proceeds from crime, terrorist financing, and the proliferation of weapons of mass destruction.
In the case of EasyPay, the regulator's claims concerned, in particular, shortcomings in the application of a risk-based approach, internal financial monitoring documents, procedures for checking new and existing clients, and risk management during remote transactions.
In addition, the NBU pointed out shortcomings in working with politically exposed persons, as well as untimely or incomplete provision of documents and explanations to the regulator.
Regarding City24, the national financial regulator reported inadequate customer due diligence and verification, insufficient application of enhanced measures to high-risk individuals, problems with internal financial monitoring procedures, and incompleteness of information about clients and their transactions.
At the same time, the NBU's public statements did not indicate that the companies had already been found guilty of money laundering. The regulator applied administrative measures to them for violating financial monitoring rules.
What could have attracted the regulator's attention
According to Ukrainian media, citing sources familiar with the results of inspections, the regulator's attention may have been drawn to transactions that showed signs of being atypical or technically improbable. In particular, it involved cases where a significant number of payments were allegedly made within a very short period of time. In some situations, the speed of transactions could have been such that a person would not have physically had time to deposit the corresponding amount of cash into the terminal.
The media also reported on the use of a single phone number to make payments in different cities with a very short time interval between transactions.
Some sources claimed that the number of transactions recorded in the reports of cash register operators might not match the recordings from cameras at terminal locations. In addition, information appeared in the media that some recipients of large sums did not include these receipts in their financial or tax reporting.
Note that the NBU has not made an official statement regarding the specific details of the case.
How EasyPay and City24 reacted to the NBU sanctions
EasyPay and City24 disagreed with the regulator's decisions and went to court. After the lawsuit was filed by the company "Swift Garant," the National Bank stated that it would defend the legality of the imposed fine in court. The regulator expressed a similar position after a court challenge by LLC "FC "Contract House."
There are currently no final court decisions on the legality of the sanctions. Thus, the fines remain valid decisions of the regulator, but their legality will still be reviewed in court.
What you need to know about EasyPay and City24
These are among the most powerful players in the payment terminal market in Ukraine. According to media reports, the EasyPay network has about 20,000 active terminals, and City24 has approximately 15,000. Together, they may control about 60% of the Ukrainian market for independent payment terminals. Due to the significant share of these companies, any changes in the rules of their operation could effectively affect the majority of terminal users in the country.
Recall
In November 2025, the Council proposed creating a "drop register." The initiative involved the creation of a Register of persons whose payment transactions require enhanced control.