Ukrainian banks will start intensively monitoring transactions of individuals starting from 1,150 euros

Ukraine’s largest banks, classified as systemic, may begin more rigorous monitoring and re-verifying one-time cash transactions involving deposits of 50,000 hryvnias (approximately 1,150 euros) or more into personal accounts before the end of the year.

This information was reported by media sources citing financial industry insiders and discussions held during closed meetings at the National Bank of Ukraine (NBU), which regularly convenes on Fridays with the heads of 15 banks’ boards.

The discussions involved banks voluntarily lowering their threshold for financial monitoring to 50,000 hryvnias for cash deposits, compared to their current thresholds. According to the official NBU exchange rate (41.24 UAH/USD), 50,000 UAH is equivalent to approximately $1,200.

Currently, mandatory financial monitoring in Ukraine starts at 400,000 hryvnias (approximately 9,202 euros). Transactions meeting this threshold are automatically reported to the State Financial Monitoring Service, and banks are required to intensively check these transactions to determine their purpose and the source of the client’s funds. Additionally, banks must scrutinize other suspicious or questionable transactions based on numerous criteria specified by NBU Directive No. 65. While the complete list of these criteria is kept confidential, public complaints from clients indicate that banks closely examine transactions related to cryptocurrency purchases or illicit business activities (such as payments for goods and services made to an individual’s card rather than to a registered business account). Banks also scrutinize users who frequently conduct multiple small transactions or utilize accounts held by third parties.

Banks monitor clients who perform numerous daily transactions (10-15 or more) or reach their internal financial monitoring thresholds. These thresholds are not legally defined and are set at each bank’s discretion, ranging from 80,000-200,000 hryvnias. When exceeded, banks may ask clients for additional documentation regarding the origin of funds and transaction nature.

The proposal to lower the monitoring threshold to 50,000 hryvnias, specifically for cash deposits, was discussed at NBU meetings and is being treated as a non-mandatory recommendation from the regulator. Although not yet officially adopted, the 15 major banks may sign a memorandum of cooperation to establish this as a unified standard. Should this happen, banks will need to adjust their internal systems for flagging and potentially blocking suspicious transactions involving individual accounts.

The primary advice for Ukrainians is to avoid handing over their bank cards to third parties. Those who frequently deposit cash and transfer funds might benefit from using multiple banks to keep individual transactions below 25,000-30,000 hryvnias, thereby reducing scrutiny from financial monitoring departments.

The list of systemic banks currently includes:

• PrivatBank
• Oschadbank
• Sense Bank
• Ukrgasbank
• Ukreximbank
• Universal Bank (Monobank)
• PUMB (First Ukrainian International Bank)
• Abank
• Raiffeisen Bank
• Credit Agricole Bank
• Ukrsibbank
• Kredobank
• OTP Bank
• Bank Pivdenny
• Tascombank.