There are more inspections in banks. Why has financial monitoring intensified and how not to become a "suspicious" client

Over 1.4 million financial transactions were subject to financial monitoring in the first three quarters of 2025 – 10% more than last year. Banks and financial institutions send an average of 160,000 signals monthly about transactions that may involve risks of money laundering or financing illegal activities. This was reported by Opendatabot.

We explain why a regular transfer or a one-time large payment may come under suspicion. What exactly raises questions for banks. We also explain why the number of checks increased in 2025.

Why has financial monitoring been strengthened

Financial monitoring ensures that banks and their clients do not conduct transactions related to shadow schemes or criminal proceeds. Therefore, banks analyze all money movements and, if necessary, ask the client to provide explanations or documents for suspicious transactions.

At the NBU is valid a system of about 70 indicators that can signal a suspicious transaction – from atypical amounts to strange wording in the payment purpose. At the same time, each bank sets these criteria in its own way, so the same transaction may raise suspicion in one bank, but go through without delay in another.

There have been no significant changes in the approaches to financial monitoring, but the regulator has strengthened supervision and clarified the rules in 2024-2025. Over the past year, the NBU has updated the norms and provided clarifications for banks, so financial institutions are improving their procedures and control tools to reduce the risk of dubious transactions.

Strengthening financial monitoring right now is a natural process. Ukraine continues to adapt EU legislation, which has increased requirements for the transparency of financial transactions and customer identification. This was stated by Maryna Pavlenko, a leading expert on financial monitoring at Globus Bank.

In parallel, the share of online and P2P transactions processed through automated monitoring systems has increased. These systems record significantly more transactions than traditional offline processes, leading to a rise in the number of transactions requiring additional scrutiny.

"This is not related to the emergence of any strict new rules, but rather to the fact that the regulator requires more detailed data, and banks have improved their own risk models," says Maryna Pavlenko.

The number of reports they transmit to regulators has indeed increased, but only within the overall market trend, she adds. All transmitted data is the result of an automated assessment of the riskiness of transactions.

"This does not create any additional inconvenience for customers: the process takes place exclusively at the level of interaction between the bank and the regulator," Pavlenko assures.

Oksana Denysenko, director of the financial monitoring and currency supervision department at Unex Bank, also says that the number of reports of suspicious transactions has indeed increased.

"From time to time, we observe so-called seasonal peaks when we work with a larger flow of cases," says Denisenko.

What transactions are most often subject to control

Most of the reports (83%, or over 1.18 million) concern so-called threshold financial transactions. These are transactions exceeding UAH 400,000 and having at least one of the legally defined characteristics. These include manifestations of separatism/terrorism, the risk of falsifying invoices in foreign economic activity, remote money laundering for terrorism, a large amount of cash in circulation, and the improper identification and sanctioning of suspicious public figures.

In October alone, materials worth almost UAH 80 billion were sent to law enforcement agencies (the Bureau of Economic Security, the National Police, the State Bureau of Investigation, etc.), which is more than for the entire last year. The State Financial Monitoring Service calls this a direct consequence of the transition to a preventive model.

"In the first 10 months of 2025, we handed over to law enforcement agencies more than a thousand reports on suspicious transactions worth over UAH 230 billion, which is four times more than in the same period last year," says Filipp Pronin, Head of the State Financial Monitoring Service of Ukraine. For this purpose, transactions totaling over UAH 1 trillion were analyzed.

Banks consider transactions suspicious if they cannot explain them even after analyzing all available customer data. "The bank's task is to understand the situation and make a balanced decision about the risks, not only for the bank but also for the client," says Anton Razumny, a member of the PrivatBank board for compliance.

He gives a typical example: when hundreds of thousands of hryvnias pass through a teenager's card in a few weeks. This often indicates that the person is being used as a "drop" (a front person for whom accounts or financial transactions are registered to conceal the real beneficiary) – and can result in criminal liability, not just blocking the transfer.

"Most often, attention is drawn to payments that do not correspond to the client's financial profile: a sharp increase in volumes, unusually large amounts, multiple small transfers, or transactions without obvious meaning," explains Maryna Pavlenko, a leading expert in financial monitoring at Globus Bank.

At the same time, actual violations are rare: they usually account for less than 1-3%. Most suspicious signals are technical triggers that the system flags for clarification. In fact, this is a primary filter, after which specialists make the final decision.

How to avoid being audited

Financial monitoring is not about "catching" clients, but about protection. And most issues only arise when data doesn't match real transactions or behavior becomes atypical.

"Be as open as possible to the bank's requests – it's about your security," emphasizes Anton Razumny.

Data renewal is one of the key requirements. For most clients, this is only needed once every five years, and it can be done in a few minutes on a smartphone. PrivatBank, for example, warns the client about the need to update information 75 days before the deadline.

The second reason for verification is a sharp deviation from the usual financial profile. If a person declares an estimated turnover of UAH 100,000 but conducts transactions worth UAH 500,000, the bank will inquire about the sources of funds. Atypical behavior also triggers a similar response.

"If more than 80% of transactions are P2P transfers to strangers or mass cash withdrawals, this will require an explanation," says Razumny.

It is advisable to notify the bank in advance about large or unusual payments and to have documents confirming their necessity. Maryna Pavlenko from Globus Bank also advises avoiding dubious counterparties and promptly responding to bank requests – this speeds up verification and removes restrictions without unnecessary delays.

Currently, requests for increasing the limit with the provision of all necessary documents on the sources of funds constitute only 0.35% of the total number of clients. This was stated by Oksana Denysenko, Director of the Financial Monitoring and Currency Supervision Department at Unex Bank.

"Informing the bank in advance about an increase in income, or about planned unusual or large transactions, significantly reduces the likelihood of their temporary suspension," adds Denisenko.