Eng 
Укр AUB Development Manager
AUB Development Manager
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.
AUB Development Manager
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
AUB Development Manager
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
AUB Development Manager
The Association of Banks of Ukraine continues to work actively to develop the country's financial system, introduce innovations and strengthen international cooperation. In July 2023, significant results were achieved in addressing issues of the banking and non-banking sectors.
Banking sector issues
The Association of Banks of Ukraine continues to work actively to develop the country's financial system, introduce innovations and strengthen international cooperation. In July 2023, significant results were achieved in addressing issues of the banking and non-banking sectors.
Banking sector issues
The Association established a working group to discuss the Central Bank Digital Currency (CBDC).
The Association's Information and Analytical Department has collected and consolidated issues to obtain clarifications from the National Bank of Ukraine on the formation and storage of mandatory reserves for documentary operations in accordance with Decision No. 752 of 23.11.2017.
Issues of non-bank financial institutions
Issues of non-bank financial institutions
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The Association sent a request to the NBU to amend Resolution No. 18 dated February 24, 2022 to facilitate the provision of payment services related to the purchase of goods from abroad for consumers who do not use payment cards.
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A response was received to a request to the NBU regarding the practical application of the provisions of the Regulation on Licensing and Registration of Financial Service Providers. The NBU noted that financial service providers independently determine the frequency and grounds for conducting inspections of compliance of managers with the requirements of professional suitability and business reputation. Amendments to Regulation No. 153 are also being developed.
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The Association reviewed the NBU's letter on the proper organization of corporate governance, efficiency and adequacy of the AML/CFT management system and internal control of the bank.
Participation in thematic events
- On July 10, 2023, a meeting was organized between representatives of banks, non-bank financial institutions and the NBU and representatives of the Verkhovna Rada of Ukraine to discuss the draft Law of Ukraine “On Personal Data Protection”. The parliamentary representatives were Taras Tarasenko, People's Deputy of Ukraine, Yulia Derkachenko, Information Rights Representative of the Ukrainian Parliament Commissioner, and Lilia Oleksiuk, member of the Committee's working group. They discussed the issues of synchronization with the GDPR and organizational changes in the work with personal data.
- On July 15, the Association of Ukrainian Banks gathers more than 50 heads of banks and financial companies for shooting, self-defense, and firefighting training.
- On July 21, representatives of Ukrainian banks meet to discuss the NBU's urgent requirements for the functioning of the AML/CFT risk management and internal control system. Proposals and problematic issues were discussed in accordance with the current legislation.
- The first meeting of the working group was held to discuss the benefits of using CBDC and the challenges to the introduction of the digital hryvnia.
Sincerely yours,
Team of the Association of Ukrainian Banks
Do you have any questions?
Please contact us:
380 (44) 516-8775
AUB Development Manager
The Association of Ukrainian Banks continues to work actively to address important issues of the banking and non-banking sectors, strengthen international cooperation and improve the level of professional training of financial institutions.
Issues of the banking sector
- In cooperation with the NBU, the issue of unblocking the practice of providing guarantees by banks to their related parties was resolved - thanks to amendments to paragraph 41 of the Resolution of the Board of the National Bank of Ukraine dated 25.02.2022
No. 23 “On Certain Issues of Activities of Ukrainian Banks and Banking Groups”;
- The NBU has started a dialogue with the Ministry of Social Policy of Ukraine to enable banks to become a point of application for social benefits and pensions in parallel with administrative service centers. The implementation of this option will expand inclusion in terms of services provided by the state;
- At the EBA's initiative, an online meeting was held with representatives of the National Bank of Ukraine, banks and processing companies to discuss ways to minimize risks to the banking business associated with the current/future sanctions against processing software companies;
- At the request of the National Bank of Ukraine, the NBU collected and consolidated comments and suggestions from non-bank financial institutions on the implementation of the Credit Register 2.0;
- A request was sent to the National Bank of Ukraine with substantiated proposals to facilitate the provision of payment services related to the purchase of goods by consumers from abroad by amending Resolution of the National Bank of Ukraine No. 18 “On the Operation of the Banking System during the Period of Martial Law” dated February 24, 2022;
- Received a response from the NBU to a request to revise one of the conditions for the use of a license to lend funds, including on a financial loan basis, determined by the regulator, namely, the removal of the obligation of financial institutions that do not provide services to individuals and do not have such business intentions to comply with the requirements for providing (disclosing) information to the consumer regarding consumer loan services
Thematic events
- The EBA organized and conducted a two-day training event “No Risk Day. Risk Management Tools in the Activities of Banks and Non-Banking Institutions: Approaches, Trends, Application” for specialized executives of banks and non-bank financial institutions. The seminar covered in detail the practical application of the risk-based approach by financial market participants, which, in particular, is the subject of special attention of the National Bank of Ukraine during inspections of financial institutions' compliance with financial monitoring requirements.
- Under the auspices of the EBA, the Digital Money Forum was held to comprehensively discuss the topic of digital money, highlighting new business opportunities, regulatory frameworks, risk management and competition issues. The forum was attended by representatives of the Ministry of Digital Transformation, the Interbank Currency Exchange, fintech companies, law firms, banks, and non-bank financial institutions. International cooperation and internal appointments were discussed;
The Association also continues to work on strengthening international relations:
- AUB Vice President Petr Pekur attended the “Restoring Ukraine” forum in Bratislava, where plans to provide Ukraine with reconstruction assistance were discussed.
- While in Brussels, AUB Vice President Galyna Haleylo took part in a briefing on “Regional Aspects of Ukraine's Recovery: Prospects for European Business” and visited the European Parliament, where she met with MEPs and foreign diplomats who are friends of Ukraine.
Sincerely yours,
Team of the Association of Ukrainian Banks
Do you have any questions?
Please contact us:
380 (44) 516-8775
