AUB News

On November 3, 2025, the Association of Ukrainian Banks held a meeting of the Committee on Compliance and Financial Monitoring (NBFU), which was attended by 33 representatives of leading financial companies. The meeting took the form of a professional discussion with substantive answers to topical questions. The Association acted as a coordinator for the development of solutions that are important for the entire industry.

Participants discussed the organization of financial monitoring in non-bank financial groups, considered the implementation of uniform internal regulatory documents (UIRDs), and focused on the practical aspects of information exchange within groups in accordance with legislation. Separate attention was paid to the consolidated supervision of the NBU, the role of the group's responsible person, requirements for the corporate governance system, risk management, and internal control.

The instrument of “delegation” and approaches to its safe use in interactions between group participants were also discussed.Iryna Popova, Chair of the AUB Committee on Compliance and Financial Monitoring (NBFU), noted that uniform regulatory documents should not only reproduce the norms, but also contain “clear procedures”: who does what and when, how data is exchanged, and what controls are in place at the group level. She concluded that it is the formalization of procedures and the coordination of approaches between group members that minimize regulatory risks and enhance the effectiveness of financial monitoring.

Participants discussed typical comments made by the NBU during inspections: untimely updates of the NDS, lack of detailed “procedures,” incomplete responses to regulator requests, discrepancies in statistical reporting, a formal approach to the risk profile of clients and companies, and insufficient automation of transaction monitoring.

They emphasized that the largest fines are usually caused by poor organization of primary financial monitoring — primarily weak ongoing monitoring of suspicious transactions and the lack of effective indicators. Attention was paid to the need to document scenarios, verification algorithms, and management reporting to prove the effectiveness of the system.They also considered the issue of practical interaction with data aggregators: they discussed the effectiveness of verification services, the possibility of prompt technical support, and the importance of having backup access channels that ensure continuity of operation even in changing conditions.

Following the meeting, it was agreed to continue collecting proposals from participating institutions for further discussion, to distribute presentation materials among Committee members, and to focus on three priorities:

• bringing the VND to the level of detailed, viable “orders”;
• strengthening the automation of monitoring and introducing proprietary indicators of suspicious transactions;harmonizing statistical and management reporting between departments.

The AUB will continue to serve as a platform for professional discussion and will coordinate the development of solutions that increase the stability and transparency of the non-banking financial sector.