AUB News

The Association of Banks of Ukraine actively continues to work on addressing key issues of the banking and non-banking sectors, implementing new initiatives and strengthening cooperation with government and international partners.

Issues of the banking sector

• The Association continues to work on the Draft Law with the initiative of additional taxation of the banking system. Meetings with bank representatives and participation in meetings of the Verkhovna Rada Committee on Finance, Taxation and Customs Policy are held to convey the position of the banking system.
• In cooperation with the National Bank of Ukraine and the State Customs Service, the Association identified problematic issues and sent relevant proposals for their resolution. 
• Based on the meeting with the banks of Ukraine and in cooperation with the Office of the President of Ukraine, the Ministry of Economy of Ukraine, Ukrainian Financial and Housing Company, it was proposed to improve the Resolution of the Cabinet of Ministers of Ukraine No. 596 of June 13, 2023 on the mechanism for guaranteeing the rights of buyers of future real estate.
• In cooperation with the financial community of Ukraine, the EBA drafted and sent a request to the National Bank of Ukraine to provide clarification on Article 14 of the AML/CFT Law of Ukraine regarding information accompanying a payment transaction or transfer of virtual assets.

Issues of non-bank financial institutions

• The NBU has processed the Draft Resolution “On Approval of the Rules for Describing the Scheme of Payment Transaction Execution” and provided proposals for improving the regulatory act. 
• Clarifications were received from the NBU regarding financial monitoring and recognition of persons as Politically Exposed Persons.
  The NBU's response to a request from the Compliance and Financial Monitoring Committee (CFMC) for clarification on reporting was processed.
• The NBU's response clarifying the application of NBU Regulation No. 65 dated 11.05.2023 was processed. 
• Proposals to resolve the issue of submitting the statistical report 4IX “Data on Compliance with Prudential Standards and Calculation of Capital Ratios of Non-Bank Financial Payment Service Providers” were developed and sent.
• Proposals to the draft resolution of the Board of the National Bank of Ukraine “On Approval of the Regulation on Prudential Requirements for Financial Companies” were developed and submitted to the NBU.

Participation in thematic events

• On November 3, a meeting was held with Ukrainian banks to discuss the issue of guaranteeing the rights of buyers of future real estate objects (MES) in accordance with CMU Resolution No. 596 of June 13, 2023. 
• On November 21, a regular meeting of the FinTech Committee was held, where practical developments on the creation of stablecoins for the Ukrainian financial system were presented. 
• On November 22, the NPL Committee held a meeting on amendments to the Bankruptcy Code of Ukraine - introduction of the preventive restructuring procedure for the debtor. 
• On November 23, a public presentation of the AUB analytics was held with the involvement of its developer, Oleksandr Markovskyi.
• On November 28, on the day of the financial monitoring system employee, a regular meeting of the Compliance and Financial Monitoring Committee (CFM) was held.

The Association of Banks of Ukraine continues to work actively to address key issues in the banking and non-banking sectors, introduce innovations and strengthen cooperation with government and international partners

Issues of the banking sector

• Based on the roundtable discussion on NPLs in the banking system, additional requests and proposals were sent to the executive and legislative authorities to improve the bankruptcy process.
• In communication with the National Bank of Ukraine, the NBU started working on the criteria for selecting customs declarations included in the customs declaration registers.
• The National Bank of Ukraine's response to the AUB's proposals to amend the calculation of mandatory reserve requirements was processed.
• A new section with visualized analytics on the banking sector of Ukraine and the possibility of comparing individual banks was introduced on the website of the Association of Ukrainian Banks.

Issues of non-bank financial institutions

• Based on the meeting of the AUB Financial Monitoring and Compliance Committee, a request was sent to the NBU with problematic issues related to the preparation of financial monitoring reports, including reports in the 2JX and 2HX formats.
  The EBA initiated work on providing suggestions and comments to the NBU's Draft Resolution “On Approval of the Rules for Describing the Scheme of Payment Transaction Execution”.
• Work has begun to increase the level of trust in non-bank financial services for consumer lending.

Participation in thematic events

• On October 18, the Association held the first discussion panel “Expectations regarding the decisions of the Monetary Committee and their impact on the banking system”.
• On October 24, the Compliance and Financial Monitoring Committee (CFC) held a meeting on financial monitoring reporting.
• In order to establish important business relations and partnerships that can play an important role in the development of the financial sector of Ukraine, the Association initiated and held the first meetings:
• On October 26, a meeting was held with the Chairmen of the Boards of banks, members of the Association.
• On October 31, a meeting was held with the CEOs of the AUB Members.

We report on the Association's activities on a monthly basis. Therefore, we would like to inform you about certain measures/steps taken by the
taken by the Association in September 2023 to address topical issues of development and protection of the financial sector.

Banking sector issues

• Thanks to the well-reasoned position of the UAB in communication with JSC “Ukrzaliznytsia”, the issue of discrimination against banks during the issuance of a bank guarantee was resolved. Relevant proposals of the Association were included in the draft procurement contracts.
• The response of the National Bank of Ukraine to provide clarifications on the bank's internal control in fulfilling the regulator's AML/CFT requirements was processed.
• Consolidated the position of the banking community on the initiative to increase the tax burden on banks. Relevant comments and proposals were sent to the Verkhovna Rada of Ukraine and the National Bank of Ukraine to protect the rights of creditors. DBA management took part in two meetings initiated by the Verkhovna Rada Committee, where these positions were voiced.
• Based on the roundtable discussion on NPLs in the banking system, a number of requests and proposals were sent to the executive and legislative authorities to improve the bankruptcy process.

Issues of non-bank financial institutions

• The Association has processed the response of the National Bank of Ukraine on the issue of Credit Register 2.0, where the regulator took into account the proposals of the BCA.
• A request was made to the NBU to detail and explain to the financial community the practice of applying enforcement measures in the form of significant fines.
• The Association proposed to the NBU to ease currency restrictions for non-bank payment service providers.
  Based on the meeting of the Compliance and Financial Monitoring Committee (CFM), an appeal was sent to the NBU regarding the practical application of NBU Regulation No. 65 dated 11.05.2023.
• The NBU's response on financial monitoring issues for non-bank institutions subject to financial monitoring has been processed.

Participation in thematic events

• On September 5, a roundtable discussion was held with Ukrainian banks and representatives of state and foreign stakeholders on the issue of NPLs in the banking system. A committee was set up on the basis of the Association of Ukrainian Banks to systematically resolve this issue, headed by representatives of JSC Ukreximbank, JSC Oschadbank, and JSC Ukrgasbank.
• On September 12, the NBU held its first discussion panel on “Expectations of the Monetary Committee's decisions and their impact on the banking system.” It was decided to hold such discussions on a regular basis.
• Two meetings of the FinTech working group were held to present the results of the work done by all participants.
  On September 26, the NBU's Compliance and Financial Monitoring Committee (CFM) held a meeting to discuss financial monitoring reporting.
• On September 27, the NBU held an event to summarize the results of the first half of the banking system and awarded more than 20 banks in various categories.
• On September 28, a roundtable discussion was held with Ukrainian banks, developers, and Ukrfinzhytlo PrJSC to find an alternative to bank guarantees with a mechanism to guarantee the rights of buyers of future real estate.

Sincerely yours,
Team of the Association of Ukrainian Banks

Do you have any questions?
Please contact us:
380 (44) 516-8775
This email address is being protected from spambots. You need JavaScript enabled to view it.

Issues of the banking sector

• The Association has processed responses from the departments of the National Bank of Ukraine to provide clarifications on the accounting of liabilities of banks for loan repurchase guarantees and the calculation of credit risk.
• The response from the NBU to the AUB's request on interaction with "Stand still" debtors was processed.
• The Association worked on the issue of discrimination of banks in the process of issuing a bank guarantee in the documents of JSC “Ukrzaliznytsia” and sent proposals to resolve this issue to JSC “Ukrzaliznytsia” and the Antimonopoly Committee of Ukraine.
  A letter was drafted and sent to the National Bank of Ukraine regarding problematic issues in the implementation of corporate governance and internal control by banks in fulfilling the regulator's AML/CFT requirements.
• A meeting of Ukrainian banks and representatives of state and foreign stakeholders was initiated to discuss the level of NPLs in the banking system. The NBU plans to set up a committee to address this issue in a systemic manner within the Association of Ukrainian Banks.
• A letter was sent to the National Bank of Ukraine with a request to provide clarifications on consolidated issues regarding Regulation #65.
• The Association raised the issue of introducing CRS (Common Reporting Standards) and elaborating on the issues for the banking sector for discussion by the banking community.
• Additional tax on net interest income: The Association initiated a meeting of the banking community to discuss and develop a common position on the draft Law No. 9656 on the introduction of an additional tax on net interest income of banks.

Issues of non-bank financial institutions

• The Association received a response from the NBU regarding the consideration of the AUB's proposal to amend Resolution No. 18 dated February 24, 2022.
• Received responses from the committees of the Verkhovna Rada of Ukraine on raising funds from individuals and legal entities to finance housing construction.
• Issues and proposals were consolidated and sent to the National Bank of Ukraine with a request to provide clarifications to Ukrainian payment systems regarding authentication and the use of enhanced authentication.
• Received responses from the Committees of the Verkhovna Rada of Ukraine and the National Securities and Stock Market Commission regarding the possibility of attracting funds from individuals and legal entities by joint investment institutions to finance the construction of housing projects by concluding preliminary real estate purchase and sale agreements.

Participation in thematic events

• A number of meetings were held with the Ministry of Social Policy and banks on a joint project to increase the inclusiveness of public services.
• On August 23, the second meeting of the FinTech working group was held with the involvement of banks, payment systems, and IT companies, where they decided on the location for testing the CBDC platform with the involvement of the Mayor of Fastiv.
• On August 28, the first meeting of the working group was held with representatives of Ukrainian leasing companies to optimize the system of fines in the leasing sector. They discussed the issue of imposing fines for traffic violations in car leasing.
• The second meeting of the Financial Monitoring and Compliance Committee (FMC) was held, where it was decided to create a working group on the basis of the Committee to standardize internal documents of financial companies.

Sincerely yours,
Team of the Association of Ukrainian Banks

Do you have any questions?
Please contact us:
380 (44) 516-8775
This email address is being protected from spambots. You need JavaScript enabled to view it.