Differences in banking supervision in the US, the EU and Ukraine
The systems for appointing bank executives in the US, the European Union and Ukraine operate according to different principles. In Ukraine, unlike in Western models, there is a significantly higher rate of rejections and greater political influence on personnel decisions.
Global banking supervision practices are based on management review procedures; however, the methods used in the US, the EU and Ukraine differ fundamentally.
In the US, control is exercised through Section 32 of the Federal Deposit Insurance Act (FDIA).
As of 2026, there have been only four recorded instances of official blocking of candidates in systemically important banks.
The number of such notifications to the Fed alone usually ranges from 400 to 600 per year for banks under its direct supervision.
If we take the 4 official vetoes in systemically important banks as a basis against the total number of applications submitted, the statistics look as follows: the rejection rate in the US is approximately 0.3%–0.5%.
The main case involved the situation at Republic First Bank, where the regulator blocked the appointment of directors due to the bank’s failure to provide a recapitalisation plan.
In the US, any White House interference in the Fed’s personnel policy automatically becomes the subject of a congressional investigation, making backroom appointments impossible.
The European Central Bank uses the Fit and Proper Protocol to assess 2,500 appointments annually.
In 2025, the proportion of outright refusals to approve appointments stood at 0.48%. The ECB’s system focuses on setting conditions (such as additional training) rather than banning professions.
The procedure is entirely depoliticised: every contact between a government representative and the regulator regarding personnel matters is recorded in public registers of lobbying meetings. Violation of this protocol leads to criminal liability for abuse of power.
In Ukraine, the supervisory system demonstrates the highest level of discretion and political interference.
As of 2026, the proportion of refusals by the NBU to approve managers stands at 18.34%. Refusals, specifically.
The main screening tool is a subjective assessment of business reputation during interviews, the results of which lack sound criteria.
Court records show 114 cases challenging the regulator’s decisions on professional unsuitability.
The influence of the President’s Office on state-owned banks, which control 53.18% of the system’s assets, is particularly significant.
Facts revealed through recorded conversations (‘tapes’) indicate that key appointments are subject to prior coordination within political centres of influence. This has always been the case, but it has now been confirmed that there are groups of influence and coordination between them.
This turns the NBU’s oversight into a tool for legitimising political decisions and exerting pressure on opponents.
Over the past year, state-owned banks have spent 48.22 million hryvnias on the services of international recruiters, whose recommendations were ignored in seven cases in favour of candidates linked to the public sector.
In other words, there are systemic risks, as professional managers are avoiding a market where the regulator’s veto power is used to carry out political agendas.
And the most interesting thing about this is that the state is doing everything it can to ensure its influence over the banking sector is not reduced.
But this raises questions for the Ministry of Finance and those responsible for organising tenders for state-owned banks.
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