On April 15, the National Bank of Ukraine reiterated what it had already stated before: banks have no right to automatically classify all Politically Exposed Persons (PEPs) as high-risk clients and unjustifiably deny them financial services. The statement itself is new. The situation it describes is not.

What the NBU says and what stands behind these words

The regulator insists on a risk-based approach: the level of client verification should correspond to the actual risk of a specific transaction, not the status in a registry. In particular, the NBU notes that banks are not obliged to demand documents about sources of wealth if the account is used primarily for salary or social benefits, and the volume of transactions does not exceed 400,000 hryvnias per month.

«Banks should not take a formal approach to servicing clients who are PEPs, members of their families and related persons, classify all PEPs as high-risk clients and unjustifiably restrict their access to financial services».

— NBU press service, April 15, 2025

Formally, this position was enshrined in amendments to financial monitoring legislation: the provision on mandatory establishment of high risk for national PEPs was repealed. Responsibility for unjustified risk elevation is theoretically provided for—a fine of up to 100,000 untaxed minimum wages.

Why banks continue to block

The practice described by lawyers diverges from the regulator's position drastically. As Interfax-Ukraine documented, not a single bank has been punished by the NBU for excessive pressure on public figures or violations of refusal procedures. In the State Financial Monitoring Service report for 2025, there is no statistics whatsoever regarding PEP refusals, blocked transactions, or actually recovered shadow funds returned to the state.

A separate problem is remote servicing: former officials are blocked from opening accounts through "Diia" under the guise of technical failures—while for other categories of clients the service works normally. Lawyers compare the situation to European practice, where the EU body AMLA establishes unified technical standards for working with PEPs. In Ukraine, the NBU, according to them, completely shifted the development of rules to the banks themselves—which breeds inconsistency and abuse.

Anti-corruption logic versus banking caution

The paradox of the situation lies in the fact that both sides appeal to the same argument. Banks are overly cautious because Ukraine has a reputation as a country with high corruption, and FATF identifies strategic shortcomings in combating money laundering. Transparency International Ukraine, in turn, insists: «where there are high risks, stricter mechanisms are needed». But the strictness of a mechanism and total blocking are different things.

The NBU is currently choosing a tactic of repeated recommendations instead of systematic oversight with real sanctions. The difference between «the regulator warned» and «the regulator punished» remains critical—and banks feel it well.

If the NBU does not publish statistics on checks and penalties for violations of PEP rights by the end of 2025, another advisory letter will remain exactly what it appears to be now: a signal for the public, not an instrument for changing bank behavior.