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Banks should not formally approach servicing politically exposed persons - NBU

Main points
  • The National Bank recommended that banks apply a risk-based approach when working with politically exposed persons.
  • Banks do not need to require documents confirming the sources of wealth of PEPs if the level of risk of the business relationship is low.
  • The National Bank recalls that if more than twelve months have passed since the termination of the performance of the PEP of prominent public functions, the bank should not take certain measures against him.
The National Bank of Ukraine. Photo: NBU
The National Bank of Ukraine. Photo: NBU

The National Bank of Ukraine (NBU) has informed that banks should not take a formal approach to servicing clients - politically exposed persons, their family members and persons associated with politically exposed persons (PEPs), classify all PEPs as clients with a high level of business risk and unreasonably restrict their access to financial services.

The National Bank provided such a recommendation to banks in a letter dated April 14, 2026, in addition to previous recommendations in letters dated February 6, 2024 and August 31, 2024, the Ukrainian News agency reports.

The National Bank emphasizes that banks should apply a risk-based approach when working with PEPs. Unreasonable use of de-risking contradicts the risk-based approach and does not contribute to financial inclusion.

The NBU also draws attention to the fact that banks do not need to request documents confirming the sources of PEP's wealth if the risk level of business relations with such a client is low, the bank has no suspicions of money laundering or terrorist financing, and the accounts opened with the bank are used primarily for receiving wages, social benefits, or the volume of financial transactions on all PEP accounts in the bank does not exceed UAH 400,000 per month.

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The NBU reminds that if more than twelve months have passed since the PEP ceased to perform significant public functions and the bank has made sure that such a client no longer bears the risk inherent in the PEP, as well as no other risks, the bank should not take certain measures against him, his family members and persons related to him. In particular, to obtain management's authorization to establish/continue business relations with the PEP, to identify sources of wealth and sources of funds, and to conduct in-depth monitoring of business relations.

By following these recommendations, banks will be able to improve their internal financial monitoring systems and increase the efficiency of risk management.

As the Ukrainian News agency earlier reported, MP Andrii Motovylovets proposes to return the norm on the automatic cancellation of the status of national public figures (PEP - Politically Exposed Persons) 3 years after their dismissal from positions that provide for such status.

In October 2023, the Verkhovna Rada adopted a draft law on lifelong financial monitoring of politically exposed persons (PEPs), abolishing the term of three years after dismissal, when this status was automatically removed.

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