AUB News

A meeting of the Compliance and Financial Monitoring Committee of the Association of Ukrainian Banks (NBFU) was held on April 23, during which industry experts discussed a number of topical issues related to work of non-bank financial institutions (NFI) in wartime conditions.

Among the wide range of topics covered at the meeting, the following should be noted:

• Approval of the procedure for using a digital signature for NFI.

The Committee discussed the fact that NFIs, unlike banks, do not have the opportunity to use a digital signature for customer verification. Committee members consider this discrimination against the NBU and called on the NBU to reconsider its position. It was decided that AUB will send an official request to the NBU with a request to make changes to the relevant regulatory acts.

• Clarification of requirements for photo and video recording during customer verification.

The committee discussed the problem of the lack of clear explanations from the NBU regarding which photos and videos can be used for customer verification. This leads to the fact that NFIs often receive comments from the NBU regarding the quality and content of photo and video materials. Committee members called on the NBU to provide clear and understandable explanations regarding the requirements for photo and video recording.

• Discussion of the risk profile of a financial institution.

Committee members emphasized the importance of a correctly compiled risk profile of a financial institution. The members of the Committee recommended that the NFU use the NBU's recommendations for drawing up a risk profile. The importance of regularly updating the risk profile was also emphasized.

Based on the results of the meeting, the Committee made a number of decisions. In particular:
• Send an official request to the NBU with a request to make changes to the relevant regulatory acts regarding the use of the NFU's digital signature.
• Contact the NBU with a request to provide clear and understandable explanations regarding the requirements for photo and video recording during customer verification.
• Recommend NFIs to use the recommendations of the NBU on drawing up a risk profile.

The issue of financial monitoring risk assessment was also discussed during the Committee meeting. Experts emphasized the importance of a comprehensive approach to risk assessment, which should include:
• Identification of products and services.
• Customer analysis.
• Assessment of geographic location.
• Analysis of service delivery methods.
• Analysis of counterparties.
• Evaluation of internal documents.
• Determination of risk factors and indicators.</ span>
• Assessment of the level of risk.
• Development and implementation of measures on mitigating risks.
• Drawing up a report on the results of risk assessment.

The participants of the meeting also discussed the issue of software for financial monitoring. Committee members suggested creating a working group to collect information about software for financial monitoring and provide recommendations to market participants regarding its application in the practical work of the NFU.
In general , the meeting of the AUB Committee was another step in the direction of improving the regulatory environment for NFIs in Ukraine. The recommendations and decisions adopted at it have the potential to improve the practical implementation of compliance standards and financial monitoring in all non-bank financial institutions of the country.