The Association of Ukrainian Banks (AUB) hosted a meeting of the Compliance and Financial Monitoring Committee dedicated to preparing for NBU inspections.
On March 18, 2026, the Association of Ukrainian Banks hosted a meeting of the Committee on Compliance and Financial Monitoring on the topic: “Preparing for NBU inspections: a risk-based approach, due diligence on clients, and the evidence base for the bank’s decisions.” The meeting was chaired by Hanna Valeriivna Horbenko, Chair of the AUB Committee on Compliance and Financial Monitoring.
During the meeting, participants discussed practical aspects of banks’ preparation for inspections by the National Bank of Ukraine, particularly the shift in the focus of inspections from the formal existence of internal documents to an assessment of the quality of their practical application. Special attention was paid to the fact that the subject of inspection today is not a single document or questionnaire, but the bank’s ability to demonstrate a comprehensive, consistent, and evidence-based decision-making system.
The discussion addressed key issues of the risk-based approach, including the logic behind establishing and reviewing a client’s risk level, documenting professional judgment, approaches to high-risk clients and PEP cases, as well as questions regarding sources of funds and sources of wealth. A separate segment of the discussion was devoted to customer due diligence, its depth, its connection to the customer’s actual behavior, and the role of the first line of defense in identifying risky transactions.
Participants also focused on issues related to the relevance of customer data, the establishment of a minimum sufficient evidentiary basis for the bank’s decisions, the role of internal documents, internal controls, and automation as part of the evidentiary basis during inspections. A separate discussion was held on exactly which documents and materials the NBU actually requests at the bank level and with respect to specific customers.
Based on the meeting’s results, the feasibility of further preparing White Paper No. 2, “Evidence and Risk Logic During NBU Inspections,” as a practice-oriented working document for the banking community was confirmed. The document is advisory in nature and has been prepared as a practical guide for banks: it will help banks better understand what approaches, documents, and internal actions are needed so that during an NBU inspection, the bank can clearly explain its decisions, support them with documentation, and demonstrate that the control system is actually functioning.
The AUB invites banks to submit practical suggestions, comments, and feedback, which may be taken into account during the finalization of White Paper No. 2 as a joint practical document for the banking community.
