Clarifications regarding payments
due to the enactment of the law
on financial monitoring

Existing bank clients do not need to undergo additional identification. The bank has already identified you as a client when concluding a bank account agreement.

If it is necessary to update your data, you will receive a corresponding notification. You should contact the bank yourself only if there have been changes to your data previously provided to the bank.

The information you provided to the bank when signing a bank account agreement is sufficient. You do not need to contact the bank yourself and provide additional documents to confirm your financial status.

Providing additional documents may arise in the event of a transaction for amounts that are atypical for you as a client (which do not correspond to your financial status, the information about which you provided when opening the account). For example, you sold real estate and want to place money on a deposit. If the amount is equal to or exceeds 400 000 UAH, the bank may ask you to indicate the source of the funds (fill out a questionnaire and, if necessary, attach a copy of the purchase and sale agreement).

Identification - provision of identification data by the client (name, date of birth, identity document data, place of residence, etc.). The client undergoes the identification procedure before concluding a service agreement. Also, by the legislation, the bank from time to time invites the client to re-identify to update the data (for example, a new address or phone number).

Verification - confirmation that the received data belongs to the client (for example, presentation of a passport, registration statement). The bank conducts verification to be sure that it is the card/account owner, and not a third party, who is conducting the transaction.

• If the amount of the cash transfer is less than 400 000 UAH, for the bank to verify the client, it is necessary to provide original documents: passport and/or RNOKPP, and/or document of residence. Reporting on the source of origin of funds if the amount does not exceed 400 thousand UAH is not required if the bank understands that the transactions correspond to the client's financial capabilities
• If the amount of the cash transfer exceeds 400 000 UAH and the payer has not been previously identified by the bank, the bank is obliged to carry out due diligence on the payer, including finding out the source of origin of funds. In addition to providing original passports and certificates of assignment of RNOKPP, the client will be offered to fill out a short questionnaire and will be asked to provide a document confirming the origin of funds (income certificate, document certifying the receipt of inheritance, purchase/sale agreement, etc.).

In PTKS FUIB, the following limits for card replenishment currently exist:

• Replenishment of a FUIB card (by card number) – up to 29999 UAH* in one payment
• Replenishment of a card of another bank (by card number) – up to 4999 UAH* in one payment
• Replenishment of a card account (by account number) in FUIB – up to 29999 UAH* in one payment

*in the absence of signs of connection of such a financial transaction with other financial transactions.

Carrying out these transactions within the specified limits does not require verification and can be carried out by the client independently.

Cash transfers of an amount from 0 to 400 000 UAH in foreign currency equivalent (amount of one transaction or the amount of all transactions in one calendar month) can be made through the cash desk. In this case, verification is required - provide a passport or other document to establish identity. It is not necessary to confirm the source origin of funds.

If the transfer amount is from 400 000 UAH and more in foreign currency equivalent (amount of one transaction or the amount of all transactions in one calendar month), it is possible to make a transaction exclusively using the SWIFT system from the current account of a resident/non-resident individual, with the provision of documents confirming the purpose of the transfer and documents confirming the source of origin of funds (provided that the transaction does not correspond to the client's financial condition).

The bank is obliged to refuse the client to open an account or carry out a financial transaction in the following cases:

• if it is impossible to identify and/or verify the client, or if the bank has doubts that the person is acting on his behalf
• if the client has not provided the documents or information necessary for proper verification
• if the client or his representative provides the bank with false information or provides information to mislead the bank
• if it is impossible to identify the person on behalf of or in whose interests the financial transaction is being carried out and to establish the beneficiary (beneficiary) of the financial transaction.

The bank has the right to refuse to carry out a suspicious financial transaction. For example, if several transactions have signs of connection.

From April 28, 2020, the legislation introduced new requirements for accompanying a transfer of funds with information about the payer and the recipient, as well as the procedure for conducting customer due diligence measures when making transfers of funds without opening an account. When making a transfer of funds without opening an account, depending on the method (cash or using a card) and the amount, the bank is obliged to:

• carry out identification and verification of the payer;
• accompany the transfer of funds with the necessary list of data regarding the payer and the recipient.

So, before making a transfer without opening an account, the bank receives information about the payer and the transfer recipient.

Payer information:

• Full name;
• unique financial transaction number (generated by the bank);
• one of the following details: (1) place of residence (or place of stay of a resident individual or place of temporary stay of a non-resident individual in Ukraine) or (2) number (and, if available, series) of the passport of a citizen of Ukraine (or other document certifying identity and, under the legislation of Ukraine, may be used on the territory of Ukraine for concluding transactions), or (3) registration number of the taxpayer's registration card, or (4) date and place of birth.

Recipient information:

• Full name;
• account number (or unique financial transaction number).

Before making a transfer, the Bank carries out due diligence on the payer - an individual - by verifying the payer's data based on official documents or information obtained from official and/or reliable sources. During the verification of the payer, the Bank copies the identity document (which, by the legislation of Ukraine, can be used on the territory of Ukraine to conclude transactions).

Re-identification and verification are not required if the person has previously been identified and verified in accordance with the requirements of the law, provided that the bank has no suspicions and/or grounds to believe that the available documents, data and/or information about the client are invalid (invalid) and/or irrelevant.

• When making transfers without opening an account (except for transfers through international payment systems) for an amount of up to 5000 UAH (equivalent) and in the absence of signs of connection of such a transaction with other transactions exceeding 5 thousand UAH (equivalent), the client's documents are not required. For such transfers, the cashier enters the information provided in the cash document form into the cash document, without additional identification data.
• When a cashier processes transfers without opening an account (except for the exceptions listed below*) in an amount equal to or exceeding 5000 UAH (equivalent), but less than 400 000 UAH (equivalent), the cashier must, based on the documents provided, establish and enter information about the payer (transfer initiator) into the cashier document.

Therefore, the client must provide the cashier with the original passport of a citizen of Ukraine (or another document that certifies the identity and, under the legislation of Ukraine, can be used on the territory of Ukraine to conclude transactions). In the absence of the required identification details in the provided document, the client must provide other documents/information that contain identification data.

The cashier is obliged to make a photocopy of the documents provided; information provided by the client in any form must be certified by him.

*Exceptions are:

• transfer of funds to pay taxes, fees, payments, fees for mandatory state pension and social insurance, penalties and fines for violating legislation to the state and local budgets, the Pension Fund, to the accounts of state authorities, local self-government bodies or to transfer funds for housing and communal services;
• transfer of funds in an amount less than 30000 UAH (equivalent) for crediting to the recipient's account solely to pay for the cost of goods, works, services, and repaying the loan debt, provided that the primary financial monitoring entity providing funds transfer services to the recipient can track the recipient using the unique accounting number of the financial transaction of the funds transfer and identify the person who concluded the contract with the recipient for the supply of goods, performance of works, provision of services, or provision of a loan.

In the case of such transfers in an amount less than 400 000 UAH, it is not required to perform identification, enter the client's identification data into the cash document (if technically possible), and make copies of the client's (representative's) documents.

Identification is the provision by the client of identification data (full name, date of birth, identity document data, place of residence, etc.). The client undergoes the identification procedure before concluding a service agreement or conducting a financial transaction.

Verification is confirmation that the received identification data (for example, a passport) belongs to the client upon presentation of the original documents. The bank conducts verification to be sure that it is the account holder, and not a third party, who is conducting the transaction.

From July 1, 2020, individual clients who are served by FUIB without opening an account can conduct cash transactions up to 400 000 UAH. To conduct transactions for an amount of 400 000 UAH or more, you must first open a current account with FUIB.

The bank has the right to request documents when making a transfer for any amount, depending on the number/frequency/volume of transactions, if the bank suspects that the client does not have the financial capacity to carry out the relevant transaction(s).

A standard verification of the sources of origin of funds takes up to 30 minutes.

Since the client does not have an agreement with the bank and is not serviced by the bank regularly, the bank has no idea about the client's usual financial condition and financial ability to carry out the relevant transactions. Accordingly, the bank will not be able to carry out a cash transaction without documents confirming the origin of the funds.

Documents* (one or more to choose from) that can be used to confirm the source of funds:

• printout of the E-declaration from the website https://public.nazk.gov.ua, certified by the signature (full name and position) of the deputy head of the department for control and operational activities (ZUOKOD)/ employee of the department for support of control and operational activities (VSKOD) with the date of printing the E-declaration;
• tax declaration with a mark of the controlling body of Ukraine on its receipt (for tax residents of Ukraine);
• information received by the client by the procedure established by law from the relevant state body, on income received in the relevant year and taxes paid from this income (for example, a certificate from the pension fund - form OK-7, a certificate from the tax authorities on the amounts of paid income and withholding taxes);
• tax declaration (income declaration) with a mark of the controlling body of a foreign state on receipt (if any), subject to the provision of documents confirming the receipt of funds to the territory of Ukraine (customs declaration, statement of a Ukrainian bank, etc.);
• notarized certificate of the right to inheritance (funds in current accounts, including deposits in another bank, income from escrow accounts);
• notarized contracts for the sale of real estate, for transactions made no later than the last 3 years (in case of compliance with the requirements of the legislation on non-cash payments in the national currency, confirmed by a bank statement);
• contracts for the sale of real estate outside Ukraine, for transactions made no later than the last 3 years, subject to the provision of documents confirming the receipt of funds into the territory of Ukraine (customs declaration, statement from a Ukrainian bank, etc.);
• real estate lease agreement between individuals, registered with the tax service (income for the current tax period is accepted, for previous periods - income must be declared);
• real estate lease agreement between a legal entity and an individual, subject to providing a bank statement, reflecting the amount of income under the above-mentioned agreement;
• other.

* Documents confirming the source of funds may be documents of family members, namely husband/wife/children/parents if there are documents confirming family ties. In the case of a transaction being carried out by a client's representative (by proxy), documents of the person on whose behalf the transaction is being carried out must be provided.

The bank is obliged to refuse a client to carry out a financial transaction in the event of:

• if it is impossible to identify and/or verify the client, or if the bank has doubts that the person is acting on his behalf;
• the client or his representative provides false information to the bank or provides information to mislead the bank;
• if it is impossible to identify the person on behalf of or in whose interests a financial transaction is being carried out and to establish the beneficiary (beneficiary) of the financial transaction.

The bank has the right to refuse to carry out a suspicious financial transaction. Financial transactions or attempts to carry them out are considered suspicious, regardless of the amount, if the bank suspects or has sufficient grounds to suspect that they are the result of criminal activity or are related to terrorism. For example, if there are several transactions that show signs of being connected.

• Clients who are served at FUIB without an open account can top up accounts/cards of other banks in cash through FUIB PTKS for the amount of up to 5 000 UAH without verification.
• Clients who are served at FUIB without an open account can transfer funds in cash up to 5 000 UAH to the account of a client of another bank through FUIB cash desk without verification.

To make a cash transfer to a client's account of another bank in the amount ranging from 5,000 UAH  to 400,000 UAH, a FUIB client who is served without an open account must provide the cashier with the original passport of a citizen of Ukraine (or another document that certifies the identity and, by the legislation of Ukraine, can be used on the territory of Ukraine to conclude transactions) and other documents in the absence of the details required for verification in the provided document. The cashier is obliged to make a photocopy of the pages of the provided document that contain the necessary identification data.

IMPORTANT: for transactions up to 30400 there is an exception - information about the payer is not set depending on the purpose of the payment (payment of utility bills, fines, pension contributions, etc.). More details in the blocks "Identification" / "Special payments"

FUIB clients who do not have an open account cannot conduct transactions in the FUIB PTKS for amounts from 5 to 30000 UAH.

Small amounts up to 5,000 UAH are not subject to financial monitoring by the bank. However, if the bank's system notices signs of connected transactions (for example, several transactions in a row), then automatic account blocking is possible. To avoid inconveniences with account blocking, payments for an amount of 5,000 UAH or more are best made at the bank's cash desk.

The law provides for exceptions for certain types of payments. Clients served by FUIB without an open account can conduct the following cash transactions at the bank's cash desk without verification:

• cash transfers – up to 5 000 UAH;
• payment of housing and communal services, payment of taxes, fines, other mandatory fees and payments to the state and local budgets – up to 400 000 UAH;
• payment for goods, works, services, payment of a loan from another bank – up to 30 000 UAH, provided that FUIB has agreements with the recipient to accept payments;
• payment of a FUIB loan in the amount of up to 30 000 UAH.