Фінмоніторинг PEP: НБУ офіційно звернувся до банків
This was announced by the National Bank of Ukraine.
In a letter dated 14 April 2026, the NBU provided banks with new recommendations on dealing with PEPs, supplementing previous guidance issued on 6 February and 31 August 2024. The regulator explicitly stated that banks must apply a risk-based approach, and that unjustified de-risking contradicts this logic and does not promote financial inclusion.
The National Bank specifically noted that banks need not request documents regarding the sources of a PEP’s wealth if the risk level of the business relationship with such a client is low, the bank has no suspicion of money laundering or terrorist financing, and the accounts are used primarily for receiving salaries or social benefits. The same rule applies if the volume of financial transactions across all PEP accounts at the bank does not exceed UAH 400,000 per month.
Another key point in the letter concerns former PEPs. The NBU has reminded banks that if more than 12 months have passed since the termination of significant public functions, and the bank is satisfied that the client no longer poses the risk inherent to a PEP and sees no other risks, then special additional measures regarding the client, their family members and associated persons need not be applied. This refers, in particular, to management approval for establishing or continuing business relationships, determining sources of wealth, and enhanced monitoring.
The NBU believes that compliance with these recommendations will enable banks to improve their internal financial monitoring systems and enhance the effectiveness of risk management. The term PEP itself is used to refer to politically exposed persons, as well as their family members and associates, who, due to their status, may require enhanced attention in the area of financial monitoring.
As reported by ThePublic, the National Bank has fined one bank and five financial companies. The reasons cited were breaches of financial monitoring rules and foreign exchange legislation.
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