The NBU has urged banks not to make it difficult to provide services to politically exposed persons
16 April 10:30
The National Bank of Ukraine has recommended that banks refrain from taking a one-size-fits-all approach to serving customers who are politically exposed persons (PEPs), their family members, or persons associated with them. This refers to the category of PEP clients for whom financial institutions should not automatically apply excessive restrictions or unjustifiably classify them as high-risk clients. This was reported by the NBU press service , according to "Komersant Ukrainian"
The NBU provided the relevant recommendations in a letter dated April 14, 2026. They supplement the regulator’s previous clarifications issued in 2024.
What the NBU recommended to banks regarding PEPs
The National Bank emphasized that banks should not take a formalistic approach to serving politically exposed persons. This means that not all PEPs should automatically be considered high-risk clients.
Banks are also advised not to unjustifiably restrict such clients’ access to financial services. The regulator emphasizes that the approach must be individualized and based on a realistic assessment of risks, rather than solely on the client’s status.
What Is a Risk-Based Approach to PEPs
The NBU emphasizes that when working with politically exposed persons, banks must apply a risk-based approach. This means that decisions regarding financial monitoring, due diligence, and restrictions must be made taking into account the specific circumstances of the client.
Unjustified de-risking—that is, excessive risk avoidance without proper grounds—contradicts this principle. Furthermore, such an approach does not promote financial inclusion and may create unnecessary barriers to accessing banking services.
When banks may not require documents regarding the sources of a PEP’s wealth
The National Bank specifically highlighted cases where banks are not required to request documents from PEPs confirming the sources of their wealth.
This is possible if the following conditions are met simultaneously:
- the risk level of the business relationship with such a client is low;
- the bank has no suspicion of money laundering or terrorist financing;
- the accounts at the bank are used primarily to receive wages or social benefits;
- or the volume of financial transactions across all PEP accounts at this bank does not exceed 400,000 hryvnias per month.
In such cases, the requirement for additional confirmation of the sources of funds is considered optional.
When a client no longer poses the risks associated with PEPs
The NBU also reminded banks that if more than 12 months have passed since the PEP ceased performing prominent public functions, and the bank has verified that such a client no longer poses the risks inherent to a politically exposed person, then no special measures should be applied to them.
This also applies to members of their family and persons associated with them.
In particular, the bank is not required to take the following measures:
- obtaining management approval to establish or continue business relationships with such a customer;
- determining the sources of wealth and funds;
- conducting enhanced monitoring of business relationships.
In other words, after the specified period ends and provided there are no risks, the bank may switch to the standard service format.
Why this is important for banks and clients
Compliance with the NBU’s recommendations allows banks to improve their internal financial monitoring systems and make risk management more effective.
For customers, this means a more equitable approach, without automatically imposing restrictions solely based on PEP status. For banks, it offers the opportunity to better balance financial monitoring requirements, legislation, and the need to ensure the accessibility of financial services.
