New restrictions on money transfers will come into effect from February 1. 7 questions and answers that will affect everyone

The memorandum strengthens control over the transactions of some clients and reduces monthly transfer limits.

New transfer limits will depend on the client’s risk level and the presence of confirmed sources of income.

Since October last year, the NBU has set a limit for Ukrainians on card-to-card (P2P) money transfers of individuals of UAH 150,000 per month.

According to the Memorandum, from February 1, 2025, restrictions will apply not only to P2P transfers, but also to outgoing transfers using IBAN details in national and foreign currencies.

They are introduced for clients without confirmed income, depending on which risk group they belong to:

• «high» risk group clients — limit of UAH 50,000 per month;
• clients of «medium» and «low» risk groups — limit of 150,000 UAH per month (from June 1 — 100,000 UAH).

At the same time, the Memorandum does not define the degree of «riskiness.» Each bank will apply its own assessment criteria when opening an account and in the process of further servicing the client.

At the same time, the document states that for clients in the «high» risk group, enhanced verification measures should be applied in each specific case. Clients in the «low» and «medium» risk groups will be verified according to a simplified procedure.

Restrictions on transfers will not affect bank clients with confirmed income (salaried clients and others), as well as volunteers whose activities are documented (in accordance with NBU Resolution No. 18 dated February 24, 2022 «On the operation of the banking system during martial law).

Limits will not apply to fund transfer transactions between two accounts that the client has opened at the same bank.

According to the head of the NBU, Andriy Pyshny, banking restrictions will apply to no more than 1% of the client base. These are exclusively those clients who have not provided documentary evidence of their income, especially those defined as «high-risk».

«If you work „on the white“, receive a „white“ salary, or can otherwise document your income or assets, nothing will change for you at all. Just as it did not change for you in October 2024, when the NBU took the first step towards solving the problem with drops, defining a general framework for all clients,» Pyshny noted.

Banks will also impose restrictions on the number of accounts (credit, deposit, and accounts for payments under government programs are not taken into account). A client without confirmed sources of income may have no more than three accounts in the same currency .

Banks will monitor payment transactions around the clock, with particular attention to night-time transactions (from 24:00 to 06:00) to identify cases of unusual financial behavior and combat fraudulent schemes.

Financial institutions will conduct an in-depth study of the business activities of newly created individual entrepreneurs (up to 6 months) of taxation group 1 and monitor account transactions according to the amount of average monthly income.

Individual entrepreneurs on the general or simplified system of 2-3 groups will be checked according to their own criteria of a risk-based approach.

The innovations from February 1 do not require updating data on bank clients' income .

«The Memorandum does not contain any requirements for additional identification, as it occurred when opening the account,» Andriy Pyshny explained.

If the client wants to make a transaction that exceeds the established limit, he must provide documentary proof of the origin of the funds.

These can be electronically generated OK5 and OK7 certificates, tax declarations, salary statements, confirmation of enrollments from government agencies, confirmed income of family members, and confirmation of volunteer activities.

Almost fifty financial institutions have joined the Memorandum on Ensuring Transparency in the Functioning of the Payment Services Market.