As well as predicted earlierIn addition, some banks have signed a memorandum to tighten control over the payments of Ukrainians, both individuals and individual entrepreneurs. It will become more difficult to use banking services for those people who do not have confirmed legal income. But the innovations will also affect law-abiding citizens.
The Memorandum on Ensuring Transparency of the Banking Payment Services Market was signed by the Independent Association of Banks of Ukraine, JSC «Oschadbank», JSC «Raiffeisen Bank», JSC CB «PrivatBank», JSC «Universal Bank» (serves Monobank) and others.
A risk level will be established for customer due diligence at the time of establishing business relationships and monitoring during servicing. And if criteria are identified that indicate a «high» risk customer, enhanced due diligence measures will be applied on a case-by-case basis. For customers with «low» risk, simplified due diligence measures are introduced (without documentary evidence of income). However, they are also subject to limits on account transfers (excluding transfers between customers’ own accounts within the same bank):
These restrictions will not apply to clients with confirmed higher sources of income and to volunteers. However, this now applies only to those volunteers who have been identified in accordance with NBU Board Resolution #18.
If there is no documentary evidence of income, the transfer limit for clients of «high» risk level should be set at UAH 50 thousand per month.
Bank customers should be prepared for the fact that they may be required to provide documentary evidence of income: OK5 and OK7 certificates, tax returns, payroll statements, confirmation of enrollment from government agencies, confirmed income of family members, confirmation of volunteer activities or other documents that can confirm the legality of the income received.
Banks will also introduce automated round-the-clock anti-fraud rules in accordance with the NBU’s recommendations, paying special attention to transactions carried out at night (from 24:00 to 06:00).
In addition, a limit will be introduced on the number of accounts opened in the same currency for one client, except for deposit accounts, credit accounts, and accounts opened for use by clients of government support programs (eVodnovnennya, National Cashback, etc.). In particular, current accounts in the same currency are limited to no more than 3 accounts for clients without documented sources of income.
Additionally, it is noted that banks, in cooperation with the NBU and government agencies, consider it necessary to provide banks and other payment service providers with access to official information through the online service «Diia» about the client’s income, court cases, etc.
It is also planned to create a centralized register of doubtful customers, from which banks will take data to study the customer when establishing or reviewing business relations. In addition, it is planned to automatically verify customer income verification, in particular, with centralized databases of government agencies and exchange data between banks using registers of government agencies.
A risk-based approach is being introduced for clients of individual entrepreneurs or individuals engaged in independent professional activities:
In addition, payment service providers will apply the practice of combining individual entrepreneurs and legal entities into a group of related companies in accordance with the National Bank’s recommendation letter.
Source: Judicial and legal newspaper
