PrivatBank, Oschadbank, Universal Bank (mono), and Raiffeisen Bank, which accounted for 64.5% of all household funds in banks and 87.5% of active payment cards as of October 1, along with the National Association of Banks of Ukraine (NABU) and the Association of Ukrainian Banks (AUB), signed a memorandum "On Ensuring Transparency in the Functioning of the Banking Payment Services Market" at the National Bank of Ukraine on Tuesday.
As reported by a correspondent from the Interfax-Ukraine agency, the document outlines the introduction of unified market practices and approaches for proper client verification and monitoring of their financial transactions. Specifically, it establishes a monthly transaction limit for high-risk clients without verified income set at 50,000 UAH starting February 1, 2025.
For medium and low-risk clients, the limit will be set at 150,000 UAH per month starting February 1, decreasing to 100,000 UAH from June 1.
This applies not only to card-to-card transfers—P2P operations, which the National Bank of Ukraine has already limited to 150,000 UAH per month at a single bank—but also to all transactions from current accounts in favor of individuals, including those to iBAN.
The signatories added that in cases of significant savings or additionally verified income, limits for clients will be set individually based on income levels, with the information planned to be collected automatically from existing resources.
Additionally, the document establishes approaches to the exchange of banking information and anticipates enhanced control over the activities of individual entrepreneurs, limiting the opening of accounts for clients without verified income to three in one currency and increasing control over nighttime payments.
The signatories of the memorandum request cooperation with the National Bank to create a centralized register of suspicious clients ("drops") and provide participants access to official information via the online service "Diya" regarding client income, legal cases, and more.
NBU Chairman Andriy Pyshnyy expressed hope during the signing that other banks and non-bank payment service market participants would join the memorandum, while AUB Chairman Andriy Dubas suggested that the overwhelming majority, possibly all 61 banks, would sign the document.
NABU Chairman Volodymyr Mudryy emphasized that this agreement does not violate competition in the market; each bank will continue to set its own tariffs, but it introduces a unified barrier against the abuse of the payment system.
"We expect that 9 out of 10 clients will not feel any changes," said PrivatBank's board member responsible for corporate business and MSMEs, Yevhen Zaihraiev, during the signing.
According to Dubas, only about 1% of clients are classified as "high" risk.
Pyshnyy noted that if the memorandum proves successful, it could replace the relevant regulation of the National Bank, which expires on April 1 of the next year.
The head of the National Bank denied information about any threats to banks that refuse to sign the memorandum.
The signatories also noted that one of the main goals of this memorandum is to increase revenues to the state budget.
Mudryy clarified that this memorandum will remain in effect during the martial law period or until the register of "drops" is established. According to the National Bank, such a register may be operational in the second quarter of 2026.
As reported, the NBU has set a limit of 150,000 UAH per month for outgoing transfers from individuals from card to card (P2P, person-to-person) for six months starting October 1, 2024, although it previously considered a stricter limit of 100,000 UAH. "The limit only applies to outgoing transfers from all accounts of the client opened at one bank to accounts of other individuals. The limit does not apply to volunteer accounts that meet the criteria defined by the resolution and to individuals whose monthly income from verified sources exceeds the established limit," the regulator stated in a press release.
It is noted that transfers between the client's own accounts at the same bank are not counted towards the limit, nor does it apply to transfers by legal entities. Operations involving IBAN details are not restricted, the National Bank clarified.
The NBU indicated that 98% of banking clients make monthly transfers that do not exceed the specified amount.
In the opinion of the central bank, the introduced limit will help minimize the use of the payment infrastructure in illegal activities, particularly involving "drop" accounts, which are a common mechanism in the shadow economy.
As reported to Interfax-Ukraine by a source in the financial market, in the first month of the national bank's restrictions, the volume of P2P operations decreased by 5.2 billion UAH, while simultaneously, IBAN transfers increased by 4 billion UAH.