Explanations as to the NBU impact measures imposed on Pivdenny Bank in November 2025

The Bank highly appreciates the regulator’s supervisory function and recognises the importance of constant improvement of the anti-money laundering and combating the financing of terrorism system.

In November 2025, the National Bank of Ukraine imposed impact measures on Pivdenny Bank in the form of two fines in the amount of 17.5 mln UAH and 1 mln UAH respectively as well as two written warnings based on the results of an off-site supervision and a scheduled on-site inspection, which took place for the first time during the restrictions caused by the COVID-19 pandemic and the onset of the full-scale war.

A fine in the amount of 17.5 mln UAH was imposed in the following directions:

1. Risk-based approach: the inspection revealed cases of non-detection or untimely detection of individual ML/TF risk criteria during the monitoring of the clients’ business relationships and financial transactions.

On-site inspection of 9 clients revealed the following results: the overall risk level of the client did not change in 7 out of 9 cases. Off-site supervision of 6 clients showed the following results: the overall risk level did not change in 5 out of 6 cases.

At the same time, the Bank’s employees investigated the real nature of the clients’ business activities during client follow-ups and did not find any reasons to suspect them of fictitious activities.

2. Due diligence and advanced checks:

• certain indicators of suspicious financial transactions not found;
• absence of certain supporting documents in client files;
• insufficiently intensive monitoring in the regulator’s opinion;
• outdated data of one client during the period of regulatory relaxations.

The Bank had full scope of information about the clients’ activities, used both public sources and own data, and analysed all the transactions for their relevance to the clients’ business.

3. Late submission of data to the NBU:

• four copies of one client’s international economic agreements;
• another client’s multi-currency credit line master agreement.

It should be noted that the Bank has submitted all the other supporting documents (invoices, customs declarations, specifications) in a timely manner.

A fine in the amount of 1 mln UAH was imposed for violations in the field of currency supervision with regards to insufficient detection (in the regulator’s opinion) by the Bank of a separate indicator of FX transactions as set forth in Regulation No. 8 of the Law of Ukraine “On Currency and Currency Transactions” that was in effect until 16.12.2023 due to varying interpretations of its content by the regulator and the Bank.

Before proceeding with the transactions, the Bank checked all the necessary documents and their compliance with the legal requirements. At the time of billing operations, the Bank had no data which could have potentially indicated the risk of non-fulfillment of obligations by foreign counterparties.

Written warnings concerned the following directions:

• development and finalisation of internal documents on the anti-money laundering and combating the financing of terrorism system;
• politically exposed persons (PEP) procedures, in particular, the lack of timely management approval for two clients;
• one typo in statistical reporting on an FX transaction.

Overall, the inspection did not reveal any facts of the Bank being used for money laundering or terrorist financing or any questionable FX transactions. Some of the observations concern similar violations and the same period, which were covered by the previous inspection and the impact measures applied by the NBU in March 2025. Accordingly, the changes implemented by the Bank based on the results of the previous inspection have not yet been fully reflected in internal processes and in client follow-ups, which only emphasises the importance of harmonising law enforcement practices and ensuring consistency in approaches to assessing banks’ activities, which, in the Bank’s opinion, will potentially contribute to strengthening trust in the financial monitoring system and increasing its overall effectiveness.

The Bank has paid the full fine, taken into account the regulator’s recommendations, and is currently in the process of implementation of an internal procedures improvement plan, a significant portion of which has already been completed.

To learn more about the NBU’s impact measures, click the link.

Pivdenny Bank shall continue acting on the principles of transparency, responsibility and complete compliance with the requirements of the Ukrainian laws and regulations of the National Bank of Ukraine.

The Bank remains a reliable financial partner for its clients and continues to perfect all the financial monitoring and risk management processes on a systemic level.