Not all PEPs are high-risk – the NBU has modernized financial monitoring for politicians, MPs, and judges
Kyiv • UNN
The National Bank clarified the rules for financial monitoring of PEPs and prohibited refusing them services without grounds. Income source checks are not required for limits up to 400 thousand hryvnias per month.
The National Bank of Ukraine has clarified financial monitoring rules for banks regarding politicians, MPs, judges, ministers, and heads of state bodies. The financial regulator dedicated a separate official letter No. 25-0010/33646, signed by Deputy Governor of the National Bank Dmytro Oliinyk, to this matter, UNN reports.
The NBU emphasized that the status of such a person itself does not mean that the bank should automatically consider them a high-risk client or refuse to serve them.
The regulator reminded that banks must assess each such client individually. That is, the decision should not depend on the person's position itself, but on what financial operations they conduct, whether there are risks of violations, and whether there are indeed grounds for enhanced control. If a bank automatically assigns the highest risk level to all PEP clients or simply refuses them services, this contradicts the law.
The letter also states that banks do not have the right to unreasonably block operations, deny access to services, or refuse to open or continue service solely due to the client's status. At the same time, they are obliged to check such persons more carefully if there are real grounds for it. If a bank incorrectly applies this approach, it is responsible for it.
Separately, the NBU explained what to do if a person no longer holds an important state position. In such a case, the bank must take into account possible risks for at least another year. During this time, additional checks may apply: for example, the bank manager's permission for service, verification of the origin of money, and enhanced monitoring of operations.
However, if after this time the bank sees that the client's operations do not raise suspicions, have a low risk, and there are no signs of abuse, then additional restrictions can be lifted. Subsequently, such a person should be checked under general conditions, like other clients. This rule also applies to family members of a politically exposed person and people associated with them.
In addition, the national financial regulator drew attention to the issue of the origin of money and assets. The bank can verify this data using documents, open information, the client's own explanations, and other available sources. At the same time, the mere fact that a person was or is an official cannot be considered an automatic explanation for the amount of their assets.
The National Bank also clarified that in some cases, a bank may not require additional checks of the source of funds. This is possible if the risk is low, there are no suspicions of money laundering or terrorist financing, and the person primarily uses the account for receiving salaries, social benefits, or if the amount of operations does not exceed 400 thousand hryvnias per month.
Finally, the NBU specifically warned banks against an approach where a financial institution simply avoids "inconvenient" clients instead of properly assessing their risks. They emphasized that such an approach is incorrect and contradicts the law.