Financial Monitoring 2026: new rules for businesses from 2 February

This update relates to Ministry of Finance Order No. 322, the entry into force of which had previously been postponed. The new procedure is now in effect and effectively reorganises the exchange of information between primary financial monitoring entities and the State Financial Monitoring Service.

The main technical change is the transition to a personal electronic account within the unified information system for the prevention of money laundering and terrorist financing. It is through this account that interaction with the State Financial Monitoring Service must now take place.

Alongside this, new forms and types of reports on financial transactions subject to monitoring have been introduced. Another important innovation is so-called case-based reporting on suspicious transactions or client activities. This means that the system is moving away from the formal transmission of individual alerts towards a more comprehensive and substantive presentation of information on high-risk cases.

Separate regulations have been introduced governing the reporting of asset freezes linked to terrorism and the proliferation of weapons of mass destruction. The State Financial Monitoring Service has already published guidelines for banking and non-banking institutions to explain exactly how to operate under the new rules.

What this means in practice

For businesses, this is not merely a technical update. The new procedure reinforces a risk-based approach, meaning that scrutiny of suspicious transactions, atypical fund movements and questionable counterparties will be more systematic.

Separately, these changes are viewed in conjunction with broader efforts to strengthen coordination between state bodies. In 2025, the State Tax Service, the State Financial Monitoring Service and the Bank of Ukraine signed a trilateral memorandum of cooperation. At the time, this covered information exchange, joint working groups and coordination in combating financial crime. Now these approaches are gradually moving from the level of agreements into practical enforcement.

This is precisely why companies face an increased risk of a swifter response to atypical payments, sharp spikes in turnover, complex transit schemes, or transactions that do not fit the usual business profile. Signs of business fragmentation may attract particular attention, where related sole traders, shared IP addresses, staff or retail outlets are analysed not individually but collectively.

Counterparties also come under additional scrutiny. If a company works with partners who have no staff, assets or signs of genuine business activity, such transactions may raise more questions. The same applies to payments to non-residents, particularly when dealing with high-risk jurisdictions.

Another area of risk involves cash flows, transactions via cash registers, and the ratio of turnover to tax liability. An atypical pattern in these areas may prompt a more in-depth analysis by the regulatory authorities.

What businesses need to prepare for

For entities subject to primary financial monitoring, the main task now is not to miss the moment when the new rules begin to operate not on paper, but in daily practice. This means updating internal procedures, training staff, checking technical readiness to work with the electronic portal, and reviewing approaches to detecting suspicious transactions.

In effect, this marks a new phase of financial control, characterised by fewer formalities and more comprehensive analysis. For the state, it is an attempt to identify high-risk transactions more quickly and enhance the effectiveness of financial crime investigations. For businesses, it is a signal to scrutinise their own payments, transaction structures, and relationships with counterparties more closely.

At the same time, the debate over the limits of such control has already begun. In particular, MP Nina Yuzhanina has publicly raised the question of whether the new coordination will serve as a mechanism for genuinely cleansing the market, or whether it will become a tool for selective pressure. It is precisely this line – between the state’s financial security and the predictability of rules for business – that will be the main test for the updated system.

As a reminder, Ukrainian banks stepped up financial monitoring of customer transactions in 2025 and plan to continue monitoring payments in 2026. As a result, citizens are advised to pay close attention to their transactions, even when dealing with small amounts.