On March 11, 2026, the Association of Ukrainian Banks hosted a working meeting of the Committee on Compliance and Financial Monitoring, dedicated to the practical aspects of banks’ preparation for inspections by the National Bank of Ukraine.
During the meeting, participants discussed current issues at the center of regulatory attention, including the application of a risk-based approach, conducting due diligence on customers, approaches to working with high-risk customers, the relevance of customer data, as well as requirements for the quality of internal procedures and banks’ preparation for inspections.
Special attention was given to three practical sessions. The first session focused on the risk-based approach and customer due diligence, including issues related to risk assessment, approaches to high-risk customers, and customers associated with PEPs. The second module focused on the timeliness of customer data, questionnaires, profiles, and general approaches to documenting decisions. In the third module, participants discussed internal documents, internal audits, self-assessments, and banks’ overall readiness for NBU inspections.
The meeting participants noted that the National Bank of Ukraine’s public practices demonstrate a continued strong focus on the quality of financial monitoring systems, the proper application of a risk-based approach, the adequacy of internal procedures, the timeliness of customer data, and the ability of banks to promptly and fully substantiate their positions with documents and materials during inspections.
Following the discussion, the importance of developing generalized practical approaches within the banking community to the most sensitive issues of NBU inspections was emphasized. Such developments should serve as the basis for the further work of the Committee on Compliance and Financial Monitoring.
During the working meeting, the concept of White Paper No. 2, “Evidence and Risk Logic During NBU Inspections,” was also presented. Its purpose is to summarize banks’ practical approaches to applying a risk-based approach, conducting due diligence on clients, documenting decisions, and preparing for inspections by the National Bank of Ukraine.
The Association of Ukrainian Banks will continue to work on summarizing market practices and preparing analytical materials aimed at enhancing the predictability, consistency, and soundness of banking practices in the area of financial monitoring.
