Clarification on making payments in connection with the implementation of the Law on Financial Monitoring

Dear Clients,

On April 28, 2020, new requirements for payments in accordance with the Law of Ukraine "On Prevention and Counteraction to Legalization (Laundering) of Proceeds from Crime, Financing Terrorism and Financing the Proliferation of Mass Destruction Weapons" came into force.  

The new requirements do not apply to the majority of ordinary transactions such as transfer of funds as payment for housing and utility services, as repayment of the loan debt, as tax payments and fees, as penalties to the budgets and the Pension Fund and will in no way affect the ability to pay by cards in trading network. In addition, the requirements of financial monitoring do not apply to cash transfers within Ukraine, if the amount of transfer is less than 5,000 UAH.

To help you understand the innovations, we have prepared answers to some of the most frequently asked questions

Do I need to undergo additional identification?

• Existing clients of the bank are not required to undergo additional identification or to submit additional documents to the bank. The bank has already identified you as a client when you signed the service agreement.
• The Bank ensures that clients timely undergo the process of updating the data, previously submitted to the bank. If necessary, you will receive a corresponding message. You should contact the bank yourself if there are changes to your data, previously submitted to the bank.

Do I need to provide proof of the funds' origin?

• The bank is obliged to clarify the source of the funds origin if the amount of transactions is 400,000 UAH or more (earlier the limit was 150,000 UAH).
• No reporting on the origin of funds, if the amount does not exceed 400,000 UAH is required if the bank understands that the transactions correspond to the financial capabilities of the client. 

If the amount of payment exceeds 400,000 UAH but the client cannot confirm the source of the funds’ origin?

• The bank records the cash flow of the client and therefore has a partial understanding of the client's financial history. On the basis of these data, as well as on the basis of the information about the level of income provided by the client during the conclusion of the service contract, the bank decides on the totals of financial transactions which are customary and acceptable to the client. If the bank understands that the total of the financial transaction corresponds to the financial capacity of the client, the bank will approve the transaction without additional documents.

How to make cash transfers through the cash desk?

• In order to make a cash transfer, the client must contact the bank branch. You need to have a Ukrainian citizen's passport or other personal identification document with you.
• If the amount of cash transfer exceeds 400,000 UAH and the payer has not been previously identified by the bank, the bank is obliged to carry out due diligence of the payer, including to find out the source of funds when analyzing the correspondence of the financial transaction to the bank's information about the client's activity. The client will be asked to fill out a short questionnaire and will be asked to provide a supporting document (income statement, inheritance document, purchase/sale agreement, etc.).

How to make cash transfers through self-service terminals?

• Cash transfers through self-service equipment up to 5,000 UAH do not require identification of the payer - the payment procedure within this limit does not change.

How to pay for utilities?

• For those clients who have paid utility bills and telecommunication services in the mobile app or in the web-version of online banking, the payment process will remain the same regardless of the amount of payment.
• Clients who have paid utility bills and telecommunication services through bank's cash desks or self-service terminals may continue to do so - identification of the payer for utility services is not required.

How to make non-cash transfers?

• The terms of non-cash transfers for FUIB clients from card to card, from card to account or from account to the account in FUIB or other banks remain unchanged. You can make transfers on your own using PUMB Online (web version or mobile application).

More detailed information on the new rules of financial monitoring has been collected on a separate page