Banks Have Tightened Controls: Why Are Ukrainians' Accounts Being Frozen Now, and What Amounts Are Being Monitored?

Bank Account Blocking and Forced Closures in Ukraine: Financial Monitoring Is Becoming Stricter

The blocking and forced closure of bank accounts became increasingly common in Ukraine last year and may become even more frequent in 2026. This is according to lawyers specialising in financial disputes and representing individuals and individual entrepreneurs (FOPs) in court. Banks are expected to further tighten their financial monitoring procedures, while customers may increasingly be required to provide certificates, declarations and other supporting documents. Telegraf examined the banks’ new requirements and reviewed specific cases in which Ukrainians ultimately lost access to their accounts and funds.

How Banks Gradually Tightened Financial Monitoring

Signs that banks were planning to significantly strengthen financial monitoring became apparent as early as the beginning of last year. Acting through industry associations — the Association of Ukrainian Banks and the Independent Association of Banks of Ukraine — banks introduced payment restrictions for individuals, subject to certain exceptions, as well as additional verification requirements for individual entrepreneurs.

In February 2025, monthly person-to-person (P2P) transfer limits for individuals were set within the range of UAH 50,000–150,000, and from 1 June the limits were tightened to UAH 50,000–100,000. The public largely accepted these measures as another necessity arising from wartime conditions.

Importantly, however, the formal source of these restrictions was not the National Bank of Ukraine (NBU), although the regulator encouraged their introduction. Unlike various wartime restrictions previously imposed directly by the NBU and potentially subject to repeal once the security situation changes, the payment restrictions adopted by banks through the relevant industry associations were introduced without a fixed expiry date and, crucially, without being formally tied to the duration of the war. As a result, they may potentially remain in place indefinitely.

This became a precursor to stricter financial monitoring of both individuals and individual entrepreneurs.

“In 2025, banks significantly strengthened financial monitoring. Transaction thresholds were lowered, the range of automated triggers used to analyse transactions was expanded, and verification algorithms became stricter and increasingly digitalised. The result has been a growing number of blocked transactions and even forced account closures. In many cases, this happens without a detailed explanation of the reasons,” Daria Lazareva, Advisor at ETERNIX Law Firm, told Telegraf.

Other lawyers point to additional factors behind the tightening of financial monitoring, including efforts to increase tax revenues amid Ukraine’s growing wartime budget deficit. They also highlight the role of the National Bank, which has intensified its supervision of banks and imposed significant penalties on financial institutions deemed insufficiently rigorous in their monitoring procedures.

According to Maksym Boiarchukov, Managing Partner at Maksym Boiarchukov & Partners, the NBU has increased both sanctions and inspections of banks, including on-site inspections and substantial fines for institutions demonstrating a formalistic approach or inadequate risk analysis.

Experts have also identified a fundamental shift in the way banks approach financial monitoring. Rather than focusing primarily on individual transactions after they occur, banks are increasingly analysing customers’ broader patterns of financial behaviour.

From KYC Checks to Automated Behavioural Analysis

Over recent years, Ukrainian lawyers have accumulated considerable experience representing individuals and businesses in disputes arising from financial monitoring, including account blocking and forced closures.

The evolution of the system can broadly be divided into several stages.

From 2019 to 2021, following the adoption of a substantially revised Ukrainian financial monitoring framework, the Know Your Customer (KYC) principle and the monitoring of typical customer behaviour became increasingly important. Banks gradually moved towards a risk-based approach, assessing each customer according to the potential risks associated with their financial activity.

In 2022, following the beginning of Russia’s full-scale invasion and the adaptation of the banking system to wartime conditions, comparatively few new financial monitoring methodologies were introduced.

In 2023, banks focused more extensively on developing and implementing their internal financial monitoring methodologies. This period also saw the introduction of certain fees related to withdrawing or transferring funds from accounts that had been forcibly closed.

In 2024, the banking sector increasingly moved towards automated behavioural analysis. Specialised systems began monitoring the transactions of individuals and businesses in real time and comparing them against customer profiles and numerous risk criteria.

Such systems can analyse account turnover, transaction frequency and timing, deviations from previous behaviour, consistency with information provided by the customer when opening the account, the economic rationale of transactions, and other potentially anomalous activity. Where the system identifies an anomaly or elevated risk, transactions or accounts may be automatically restricted pending further review.

In 2025, banks increasingly focused on combating business fragmentation schemes used to minimise taxation, as well as so-called “money mules” — individuals whose accounts are used by third parties in potentially unlawful schemes.

Financial institutions have also increasingly incorporated international Anti-Money Laundering (AML) standards into behavioural monitoring. As a result, banks may assess not only the customer or individual entrepreneur, but also broader transaction chains and financial relationships involving relatives, friends, business partners and counterparties.

New technologies, including artificial intelligence, are increasingly being incorporated into these processes.

“What we are effectively seeing is a transition from isolated responses to large-scale, more systematic financial intelligence. Financial monitoring in Ukraine has become significantly more active and structurally stricter,” Daria Lazareva noted.

What Can Trigger Account Blocking?

Banks often emphasise that accounts may be restricted or closed when customers fail to provide the full package of requested documents. In practice, however, the range of potential triggers is considerably broader.

Among the most common reasons identified by lawyers are transactions inconsistent with the customer’s profile, unusually large one-off payments, sudden activation of previously inactive accounts, significant changes in financial behaviour without a clear explanation, and the use of personal accounts for business purposes.

Additional risks may arise from offshore transactions, cryptocurrency operations, P2P transfers involving foreign exchanges, transactions with high-risk jurisdictions, sanctions-related exposure and financial activity that cannot readily be reconciled with the customer’s declared lawful income.

Banks are also increasingly paying attention to unusually intensive transaction activity, discrepancies between a customer’s actual activity and their digital financial profile, unusual digital footprints, and transactions involving foreign neobanks.

Another increasingly important factor is the customer’s indirect relationship with potentially high-risk counterparties. Even where the customer’s own activity appears legitimate, a bank may analyse the entire transaction chain and identify risks associated with second-level counterparties.

Digital infrastructure may also form part of anti-fraud analysis. For example, banks may assess network and device-related indicators when identifying potentially suspicious activity.

Algorithms may additionally flag unusual mathematical patterns in transactions, such as repeated transfers of identical or rounded amounts, where such activity appears inconsistent with the customer’s ordinary financial behaviour.

Typical Disputes Involving Individuals and Individual Entrepreneurs

For individuals, common disputes include blocked cards following transfers from relatives or colleagues, charitable donations, cryptocurrency purchases, large corporate payments, bonuses, compensation or other transactions considered inconsistent with the customer’s usual profile.

In some cases, social benefit or pension accounts may also be affected where other transactions associated with the same customer trigger enhanced monitoring.

Another category of disputes concerns forced account closures accompanied by substantial fees for transferring or withdrawing the remaining balance.

For individual entrepreneurs, the most common issues include suspected business fragmentation or tax avoidance, transactions between multiple FOPs, turnover inconsistent with the declared type of economic activity, the use of business accounts as intermediary or distribution accounts for groups of individuals, and disputes concerning foreign trade transactions.

Banks may request foreign trade agreements, invoices, customs declarations, information confirming the source of funds received from non-residents, and other supporting documentation.

Transaction Amounts and Financial Monitoring Risk

According to observations shared by Daria Lazareva with Telegraf, certain general patterns can be identified for individuals:

• Up to UAH 30,000 per month: the likelihood of additional scrutiny is generally relatively low if the customer’s profile corresponds to the actual inflows. Questions may nevertheless arise where a person declares no official income but regularly receives funds.
• UAH 30,000–100,000: much depends on the structure of transactions — who is making the payments, how frequently they occur, their amounts and whether they correspond to the customer’s declared activity. Banks may request supporting documentation.
• Above UAH 100,000–200,000: transactions are considerably more likely to attract enhanced scrutiny. Banks may request explanations, evidence of the source of funds, information regarding the customer’s business model and confirmation of tax compliance.

“However, it is important to understand that these figures are only indicative. No bank publishes the exact algorithms underlying its risk-based approach. Specific financial monitoring triggers constitute restricted information. The actual likelihood of additional scrutiny is determined not only by the amount involved, but by a combination of factors,” Lazareva emphasised.

Lawyers also note that the intensity of financial monitoring may differ significantly between financial institutions and may change following supervisory inspections by the National Bank of Ukraine.

Telegraf will continue to follow developments in financial monitoring. A subsequent article will examine possible ways of resolving disputes with banks and recovering access to funds held in blocked accounts.