AUB News

On January 12, within the framework of the Compliance and Financial Monitoring Committee of the Association of Ukrainian Banks, a working meeting of the working group was held, dedicated to KYC standards and customer onboarding, taking into account the practice of inspections in 2025. The meeting was preparatory in nature and was aimed at developing materials for the upcoming meeting of the Committee.

Participants discussed approaches to customer profiling as a basis for forming an understanding of the customer and an initial risk assessment. The emphasis was placed on the practical minimum of information sufficient to work with the customer, without excessive requirements and formalism.
Separate consideration was given to approaches to profiling individuals, individual entrepreneurs, and legal entities, with a focus on understanding the economic content of the client's activities and expected financial behavior.

The second block of discussion was devoted to updating client data in the process of customer service and the logic of risk review. It was emphasized that updating should be a tool for verifying the relevance of risk assessment, rather than a formal collection of documents.
Particular attention was paid to determining when an update confirms that the risk remains unchanged and when it is grounds for its review or escalation, as well as the role of management decisions in this process.

The third block was devoted to summarizing typical comments that banks encounter during inspections in 2025. Issues discussed included the formal approach to KYC, the lack of logical connection between the information collected and risk assessment, data updates without clear management conclusions, and insufficiently justified risk escalation.
The issue of responding to negative information from open sources within the framework of a risk-based approach was also raised.

The results of the work confirmed the advisability of preparing White Paper No. 1 “Basic Principles of KYC,” which should summarize the approaches developed and be used as a guideline for banks that are members of the Association.

The working group's materials will be submitted for consideration by the Financial Monitoring Committee, scheduled for January 21.