Eng 
Укр The AUB and NABU provided clarification regarding the Memorandum “On Ensuring Transparency in the Functioning of the Banking Payment Services Market” to Payment Service Providers – participants in the Memorandum
In order to avoid ambiguous interpretations of approaches to working with individuals referred to in the Memorandum “On Ensuring Transparency in the Functioning of the Banking Payment Services Market” and to eliminate possible discrepancies in practical application, provided clarification to Payment Service Providers – participants in the Memorandum – regarding the implementation and application of practices that comply with the principles of transparency declared in the Memorandum, namely:
- The parties to the Memorandum shall refrain from imposing restrictions on the transfer of funds to individuals – volunteers who are identified in accordance with Resolution No. 18 of the Board of the National Bank of Ukraine dated February 24, 2022. Restrictions shall not apply provided that there are relevant sources of income and transparent purposes for the transfers.
- Participants are encouraged to post information on their websites about the non-application of restrictions on volunteer operations, as well as about mechanisms for individual consideration of requests. This will help build trust and reduce the number of user inquiries.
- In cases where customers receive income from various verified sources (salary, sale of property, deposits, etc.), Participants must apply limits on an ongoing basis for salaried customers if the salary exceeds the limits and individual one-time limits on transfers of funds to their own accounts or accounts of first-degree relatives, if the accumulated total verified income exceeds the established limits from salaries, real estate sales, etc. At the same time, the application of such limits should be based on the principles of proportionality, transparency, and non-discrimination.
Compliance with the provisions of the Memorandum does not preclude banks from applying a risk-based approach in accordance with the requirements of applicable law. However, such an approach should not lead to mass or unjustified blocking of payments by volunteers or individuals with legal and verified income.
You can read the explanatory letter at the following link: https://drive.google.com/file/d/1HdphGQgXv8B73X0cdESgNROjTL7eaDfR/view?usp=sharing
