AUB News

The Association of Ukrainian Banks has approached the NBU with a question regarding the application of Articles 20–21 of Law of Ukraine No. 361 concerning the financial monitoring of transactions by customers who split them into amounts below the threshold in order to avoid monitoring.

In this regard, the question was raised as to whether such transactions can be considered threshold transactions or transactions with signs of suspicious financial transactions, and what further actions should be taken by primary financial monitoring entities.
Following consideration of the Association's appeal, the National Bank of Ukraine provided an official clarification confirming that the decisive condition for classifying a financial transaction as threshold is the amount of the transaction, which must be equal to or exceed the established amount if the relevant sign is present.

The National Bank of Ukraine also emphasized that primary financial monitoring entities must take additional measures if the fact of fragmentation of financial transactions is established.
The NBU's position (letter dated December 31, 2025, No. 25-0009/10059) can be found on the regulator's official website in the section “Regulatory Framework / Practical Application of Article 20 of the Law on AML/CFT.”

Or via the direct link:
https://bank.gov.ua/ua/legislation/Notice_31122025_100509%20.

The clarification received contributes to the formation of a unified law enforcement practice in the financial sector. The Association of Ukrainian Banks systematically supports the financial sector and represents the interests of primary financial monitoring entities before the regulator.