New approaches of the National Bank of Ukraine (NBU) to imposing penalties for violations in the field of combating money laundering

11/07/2023

The National Bank of Ukraine has conducted a comprehensive review and update of its approaches to imposing penalties on banks for violations in the field of combating money laundering (AML) and the currency legislation.

As part of these changes, fines have been established for the most common violations in the AML field, including:

  1. Violations of AML legislation regarding risk management - up to 50 million UAH.
  2. Non-compliance of internal documents on AML with legislative requirements - up to 1 million UAH.

In addition, the maximum amounts of fines for key AML violations have been revised and increased, including:

  1. Violations of customer due diligence requirements - up to 50 million UAH.
  2. Violations of AML legislation regarding payment transactions / fund transfers - up to 10 million UAH.
  3. Inadequate application of a risk-based approach to politically exposed persons (PEPs), including setting an unjustified risk level and taking disproportionate measures according to the risk category - up to 10 million UAH.

This comprehensive review and update of approaches to imposing fines for specific AML and currency legislation violations will help prevent non-compliance with legislative requirements by banks, increase accountability for non-compliance or inadequate compliance, and enhance the effectiveness and deterrent nature of the measures to promote a change in the approach to proper organization of bank operations and risk management.

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