The financial sector discussed the specifics of applying Article 15 of Law No. 361 regarding the refusal to establish (maintain) business relationships and conduct financial transactions, as well as other current issues related to the implementation of financial monitoring legislation.
On March 17, 2026, the Association of Ukrainian Banks, in collaboration with VSchool, organized an online event on the topic: “Specifics of the application of Article 15 of Law No. 361: refusal to establish (maintain) business relationships and conduct financial transactions.”
The offline event brought together over 220 representatives from the financial monitoring departments of banking and non-banking institutions to discuss the specifics of applying Article 15 of Law No. 361 regarding refusal to establish (maintain) business relationships and conduct financial transactions.
The event examined in detail the key grounds for refusal provided for by law, with an emphasis on their practical application in the activities of primary financial monitoring entities.
The event provided a detailed examination of the key grounds for refusal provided for by law, with an emphasis on their practical application in the activities of primary financial monitoring entities.
Particular attention was paid to cases where primary financial monitoring entities are required or have the right to refuse to conduct financial transactions. In this context, both regulatory requirements and the practical aspects of their implementation were discussed.
Participants also discussed the practical aspects of information exchange with the State Financial Monitoring Service, particularly regarding the submission of information.
Significant attention during the event was devoted to the organization of internal procedures for primary financial monitoring entities, including maintaining refusal registries, ensuring their protection against unauthorized access, establishing procedures for entering and correcting information, recording the grounds for decisions made, and properly documenting the actions of authorized employees.
A separate section was devoted to the resumption of client services after the grounds for refusal have been eliminated. Participants reviewed the conditions under which business relations may be resumed, including when a client provides a complete set of documents, clarifies or corrects previously submitted information, and when the risk level is reassessed based on updated data.
Following the main part of the webinar, a discussion took place in the “Voice of the Financial Sector” format, during which participants shared practical experiences and identified challenges in applying the legislation. Such discussions are vital for a dynamic professional dialogue, enabling the rapid exchange of ideas, the consideration of participants’ perspectives, and more effective collaboration compared to communication via chat formats.
The format of short webinars for the financial monitoring community is extremely important, as it allows for a systematic focus on current topics and practical challenges, ensuring the effective use of participants’ time. This approach enables a constant focus on key issues and allows for prompt orientation toward the most important developments in the field of financial monitoring.
