NBU Sanctions Against Banks and Financial Companies: What Is Behind Record Fines and How the Market Reacts
National Bank of Ukraine published a list of record sanctions imposed on banks and non-banking financial institutions. Control over financial monitoring and the enforcement of currency supervision have intensified against the backdrop of war, attempts to circumvent sanctions, new requirements for transparency, and reputational risks for the market.
The NBU has imposed fines and written warnings on three banks and ten financial companies. The reasons include violations of anti-money laundering legislation, counter-terrorism financing, currency regulations, as well as deficiencies in reporting. The largest fine was imposed on Asvio Bank over UAH 9 million in total.
Asvio Bank: The Leader of the Anti-Rating
According to official data, Asvio Bank received several fines at once:
- UAH 7.7 million for violations of risk-based approach requirements, inadequate financial monitoring, and insufficient customer and transaction checks.
- UAH 1 million for untimely and incomplete submission of reliable information and documents to the National Bank.
- UAH 400,000 for violations of currency supervision and the identification of risky currency operations.
The total amount of sanctions exceeded UAH 9.1 million a record figure for the sector in 2024.
Motor-Bank: Repeated Violations
Motor-Bank was fined UAH 6.2 million for insufficient customer due diligence, violation of the risk-based approach, and untimely submission of data to the regulator. Additionally, UAH 51,000 for failing to provide information on currency transactions, as well as a written warning for poorly implemented internal documents on financial monitoring.
Oschadbank: Reporting Issues
Oschadbank received a UAH 500,000 fine for late responses to NBU requests, which violated the deadlines for providing information on anti-money laundering issues.
Sanctions for Non-Banking Institutions: The Scale of the Problem
The largest fine UAH 16.6 million was imposed on Ukrainian Payment Resources LLC for serious violations in primary financial monitoring and risk management. Key claims included the lack of proper risk assessment, weak financial transaction control, unreliable reporting, and the absence of automated monitoring systems.
PZU Ukraine Insurance Company (UAH 595,000) was fined for ignoring risky clients and insufficient due diligence of persons linked to sanctions or politically exposed persons.
Dozens of companies pawnshops, financial companies, insurers received fines ranging from UAH 50,000 to 400,000 for late reporting, breaches in cash operations video surveillance rules, or deficiencies in internal documentation.
“Alliance Bank”: A Precedent of Strong Judicial Resistance
The situation with Alliance Bank is especially telling. In November 2024, it was fined UAH 15.05 million for insufficient due diligence of high-risk clients, providing unreliable information, and violating the risk-based approach. The bank challenged the sanctions in court, and the National Bank publicly declared its readiness to defend its decision.
This story is particularly resonant considering that, in recent years, the number of court rulings in favor of the state in disputes with banks over financial monitoring has been growing in Ukraine. However, Alliance Bank demonstrates a firm stance and willingness to defend its interests to the end. And while we do not support violations in the sphere of financial monitoring, the very fact of legal resistance shows: banks do not accept exorbitant fines unconditionally and are ready to use legal means for their defense. For the market, this is a signal that the struggle for balance between regulatory requirements and the rights of institutions is only intensifying.
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The Depth of the Problem: Why Is the NBU Tightening Control?
The financial monitoring system in Ukraine is a matter of the country’s international reputation, protection against terrorism financing, and compliance with FATF and EU requirements. Yet, at the same time, it is also a field of conflict of interest, as banks and financial companies are required to ensure maximum transparency and strict risk control even in the difficult conditions of war and economic constraints.
Regulatory pressure is steadily increasing, and the fines are the highest in recent years. This is why we are seeing more legal disputes: some banks and companies disagree with the scope of requirements or the regulator’s interpretation.
The Ukrainian financial market has entered a new stage:
- Requirements for financial monitoring and currency control are steadily increasing.
- The level of sanctions for violations has reached record highs this puts pressure on business, but also creates transparency for international partners.
- Banks and companies are increasingly defending their rights in court, which is a sign not only of corporate independence, but also of the emergence of a mature culture of defending interests within the legal framework.
The market has received a clear signal: there will be no easing of requirements, and responsibility is real. However, legal disputes and public discussions about the fairness of certain decisions show that the balance between state interests and business protection remains a pressing challenge.
One way or another, it is precisely the quality of procedures, transparency, compliance with FATF, and the willingness to fight for their rights that will determine which institutions remain on the market tomorrow.
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