"For coffee" and "repayment of debt": what words can cause a payment to be blocked

Since October 1, the National Bank of Ukraine has introduced a number of changes to Open Banking technology – a system that allows banks to securely exchange customer data with their consent. Financial institutions have received more tools to control the transparency of each transaction.

However, Ukrainians have started reporting a new wave of payment blockages en masse. Banks explain this by increased attention to transfers and the use of so-called "trigger" words in the payment purpose.

Financial institutions are increasingly checking not only the transactions themselves, but also the text that accompanies the payment. This, according to users, leads to account freezes and requests for additional explanations.

LIGA.netI figured out how exactly banks identify risky transactions, what wording in payments can block a transfer, and whether it is possible to appeal such actions.

How does financial monitoring work?

Financial monitoring is a system responsible for ensuring that banks and their clients do not handle money from shadow schemes or criminal activities. As part of financial monitoring, not only the amounts but also their purpose are analyzed.

"This is standard practice in financial monitoring, aimed at identifying risky transactions," explains Olena Kireyeva, Head of the Financial Monitoring Department at OTP Bank.

However, identifying a suspicious transaction is not limited to automatic keyword detection, she explains. Banks always conduct a comprehensive analysis of money movements and, if necessary, contact the client for clarification and supporting documents.

To detect suspicious transactions, the NBU (National Bank of Ukraine) has established a system with 70 indicators, according to the National Association of Ukrainian Banks (NAUB). Unusual words in the payment purpose and atypical amounts are just some of them.

However, each bank adapts this set of rules to its own needs, which is why the same payment can "work" differently in different banks.

Usually, the bank doesn't block the client or their card, but a specific transaction – the transfer itself simply gets stuck for the duration of the verification. This process can take up to two business days while financial monitoring specialists clarify the details.

What not to write in the payment purpose field.

A single word is unlikely to trigger anything, but certain combinations of words or symbols can attract the attention of the financial monitoring system. This is according to OTP Bank.

Such words in the payment purpose may include: "promissory note", "bonds", "forms", "shares", "certificates", "insurance", "for crypto", "currency exchange", "debt repayment", "exchange", "assistance", "rate" or "private payment".

Also, seemingly innocent purposes can fall under control: "for coffee," "for food," "girlfriend's salary," and others.

"Such words are considered potential indicators of financial instruments or atypical transactions," Kireeva emphasizes.

Legal entities are most often included in the high-risk group – banks scrutinize their transactions more closely. This is due to the larger volumes of transfers and more complex payment schemes.

The bank advises clients to ensure that all transactions correspond to the declared types of activity, and, if requested, to promptly provide documents and explanations that confirm the economic substance of the transactions.

If this is a private, non-commercial payment between individuals, then there is no documentary evidence in the classic sense (invoice, contract, act). In this case, an explanation in free form can be provided.

For example: "Transfer of 200 UAH to a friend – partial reimbursement for the coffee she paid for me during our meeting on November 2, 2025."

How to avoid being blocked

Care must be taken in formulating payment descriptions. This has become especially important since the beginning of active... fighting against dropsThis is according to Fedir Kolosov, an associate lawyer in the dispute resolution practice at Mitrax.

The main problem is the lack of clear legislative regulation. The criteria for assessing client risk are essentially determined by the banks themselves, he says.

In laws The law "On Prevention and Counteraction of Legalization (Money Laundering) of Proceeds of Crime..." lacks clearly defined criteria for account blocking. According to the document, banks themselves are responsible for defining the criteria for blocking accounts and making the corresponding decisions. Kolosov says that this is inconvenient for both clients and banks, as the number of cancelled blocks and transactions is increasing.

However, the bank's decision can be appealed – the best approach is to go to court. According to the lawyer, as a rule, it is possible to appeal not the fact of the blocking itself, but how the bank considered the submitted documents – whether it violated the deadlines, or whether it correctly completed all the formalities.

Usually, the court ultimately unblocks the account or funds. However, when it comes to compensation for potential lost profits, such practice is almost non-existent in Ukraine, says Fedir Kolosov.