On the last day of February, CEDEM held a webinar for the representatives of NGOs and charitable organizations “Stress-Free Financial Monitoring: How Can CSOs Get Around Banking Problems? 

At the event, 17 participants learned the causes of problems they may have due to the financial monitoring measures that banks apply. They also received tips and learned how to protect their CSOs from possible banking problems due to financial monitoring.

Participants strengthened their ability to solve banking problems by acting in the Ukrainian legal framework.

The webinar included a practical part where participants practiced solving cases of financial monitoring problems. 

At the end of the webinar, 90% of participants knew that it is better to communicate with the bank through official correspondence; 100% knew what financial monitoring measures the bank can apply to their organizations; 73% knew how to properly protect the rights of their organizations in the legal field if the bank violated them.

See information about possible financial monitoring measures that a bank can apply to an organization’s banking operations, as well as our tips on how to act if your organization has problems with a bank, in our infographic.

The recording of the webinar can be found at the link.

Suspension of a financial transaction by the bank

The bank is obliged to refuse to carry out the transaction if the customer has not provided the documents or information necessary for customer due diligence.

The bank has the right to refuse to carry out a suspicious financial transaction.

N.B. The bank has the right to request additional documents or explanations on the suspicious transaction or customer’s activities within 2 months from the date of detection of the transaction.

The infographics was created as part of the Project Ukraine Civil Society Sectoral Support Activity implemented by the Initiative Center to Support Social Action “Ednannia” in partnership with the Ukrainian Center for Independent Political Research (UCIPR) and Centre for Democracy and Rule of Law (CEDEM) with the sincere support of the American people through United States Agency for International Development.

Bank asset freezing

The AML/CFT law does not provide for the freezing of bank accounts, only assets (money in the account)

A freeze can be imposed if the bank suspects that the assets are linked to terrorist financing. At the same time, the client is not warned about blocking.

 ! Asset freezing should not be confused with customer service suspension!

N.B. The financial monitoring legislation does not provide for a mechanism for temporary service suspension. The bank has the right to refuse to carry out a financial transaction in cases provided for by Article 15 of the Law.

At the same time, the bank in its internal documents may provide for the procedure of temporary service suspension, establishing a reasonable period of such suspension and not prohibiting mandatory payments. (NBU Clarification)

The infographics was created as part of the Project Ukraine Civil Society Sectoral Support Activity implemented by the Initiative Center to Support Social Action “Ednannia” in partnership with the Ukrainian Center for Independent Political Research (UCIPR) and Centre for Democracy and Rule of Law (CEDEM) with the sincere support of the American people through United States Agency for International Development.

What should you do if a transaction or account is blocked?

If your transaction has been frozen for longer than 2 days and the bank has not contacted you, you should make a written request to the bank! They are not obliged to inform the client of the details of the decision to stop the transaction!

Keep communication with the bank in writing – correspondence an serve as evidence if you have to challenge the bank’s actions.

If the bank asks for additional documents or explanations of the transaction – provide them if possible. If there is no possibility to provide documents or it takes additional time – justify the reason, ask to extend the deadline for submitting the documents.

The infographics was created as part of the Project Ukraine Civil Society Sectoral Support Activity implemented by the Initiative Center to Support Social Action “Ednannia” in partnership with the Ukrainian Center for Independent Political Research (UCIPR) and Centre for Democracy and Rule of Law (CEDEM) with the sincere support of the American people through United States Agency for International Development.

If the situation cannot be resolved and you consider the bank’s actions illegal, you can appeal to the NBU through the following channels:

By e-mail stating the situation and why your rights are violated at nbu@bank.com.ua (you need to sign the e-mail with an electronic signature and add a copy of your correspondence with the bank). You can copy it to your bank’s email.

By regular mail to the postal address: 9 Institutska Street, Kyiv, 01601 (do not forget to attach a copy of correspondence with your bank)

Via the hotline: Via the electronic form on the website:

0 800 505 240

The response period is 30 days.

N.B. We advise you to complain in writing

The infographics was created as part of the Project Ukraine Civil Society Sectoral Support Activity implemented by the Initiative Center to Support Social Action “Ednannia” in partnership with the Ukrainian Center for Independent Political Research (UCIPR) and Centre for Democracy and Rule of Law (CEDEM) with the sincere support of the American people through United States Agency for International Development.

The expert discussion was organized as part of the Project Ukraine Civil Society Sectoral Support Activity implemented by the Initiative Center to Support Social Action “Ednannia” in partnership with the Ukrainian Center for Independent Political Research (UCIPR) and Centre for Democracy and Rule of Law (CEDEM) with the sincere support of the American people through United States Agency for International Development.