New limits and bank checks starting February 1: who may have their card blocked?

Starting February 1, new restrictions on bank transfers will come into effect, established according to the memorandum of the largest Ukrainian banks. If a bank client does not have proof of income, their accounts may be blocked. We explain what the new limits will be and who may have their accounts blocked.

What is the banks' memorandum

On December 10, 2024, four of the largest banks in Ukraine signed a memorandum "On Ensuring Transparency in the Operation of the Market for Banking Payment Services." These banks are:

• PrivatBank;
• Oschadbank;
• Raiffeisen Bank;
• Universal Bank (Monobank).

Subsequently, other banks joined the memorandum:

• OTP Bank;
• Pravex Bank;
• PUMB;
• Tascombank and others.

The memorandum allows these banks to independently set limits on transfers, including operations by IBAN, depending on the client's risk profile.

What are the bank transfer limits starting February 1

The limits will be as follows:

• for "high" risk clients – up to 50,000 UAH per month;
• for medium and low-risk clients – up to 150,000 UAH from February 1, 2025, and up to 100,000 UAH from June 1, 2025.

Additionally, the banks that signed the memorandum will impose restrictions on the number of accounts opened in one currency for a single client. This refers to no more than three accounts for clients without documented sources of income. This does not apply to deposit accounts, credit accounts, and accounts opened for clients using state support programs ("eRecovery," "National Cashback," etc.).

Who is considered a "high" risk client

The memorandum does not define high-risk clients, according to EP.

According to the law "On Preventing and Counteracting the Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism, and Proliferation of Weapons of Mass Destruction," such clients are recognized as:

• those residing or registered in states that do not meet international financial monitoring requirements, offshore zones, or aggressor countries (Russia and Belarus), as well as those connected with aggressor countries;
• foreign financial institutions (except for financial institutions from the EU and FATF member countries);
• those against whom sanctions have been imposed, etc.

The relevant regulation from the National Bank adds to the risky clients:

• clients engaged in virtual asset activities;
• individuals suspected by the bank of money laundering or financing terrorism;
• clients suspected by the bank of belonging to shell companies engaged in fictitious activities;
• clients conducting financial transactions with residents of countries that violate FATF requirements.

In summary, a bank will consider a client risky if they lack official sources of income but significant amounts of money flow through their accounts. Clients whose official income is significantly lower than the amounts actually passing through their accounts may also be classified as such.

Moreover, this includes a large number of "small" transfers from card to card or via IBAN, especially if such transfers occur frequently throughout the day.

Who is not affected by the restrictions

The limits do not apply to clients with verified sources of income, including salaried clients, as well as volunteers.

How to confirm your income

To confirm income, the following can be used:

• tax declarations;
• payroll statements;
• confirmation of deposits from government bodies;
• information about the income of family members;
• certificates OK5 and OK7 generated in "Diia," etc.

Consequently, banks will intensify checks on individual clients and certain categories of individual entrepreneurs, particularly those established no earlier than six months ago.

The limit can be increased upon the client's request, but this requires documented proof of income sources.