New financial monitoring rules

On 02 February 2026, Order No. 322 of the Ministry of Finance dated 4 June 2021 comes into force, updating the approach to cooperation in the field of financial monitoring.

In accordance with this Order, a new Procedure for information exchange between subjects of primary financial monitoring and the State Financial Monitoring Service of Ukraine, as well as a Procedure for creating a personal account for subjects of primary financial monitoring and accessing the e-account of the financial monitoring system, shall come into effect.

The document defines the mechanism for electronic information exchange between subjects of primary financial monitoring (SPFM) and the State Financial Monitoring Service. Its provisions are also related to the introduction of the SPFM electronic cabinet and provide for the transfer of SPFM communication with the State Financial Monitoring Service to a continuous digital format with round-the-clock access.

The Order provides for

• the introduction of new formats for reporting financial transactions subject to financial monitoring, as well as the transfer of other information related to its implementation;
• the obligation for SPFM to apply a risk-based approach when conducting due diligence on their customers;
• the transition of SPFM to reporting on specific cases of suspicious transactions or activities of their customers;
• the submission of reports on the freezing of assets related to terrorism, its financing, as well as the proliferation and financing of weapons of mass destruction.

In connection with the entry into force of the Order and requests from the SPFM regarding the procedure for submitting information on financial transactions that are both threshold and suspicious, the State Financial Monitoring Service has prepared relevant recommendations for banking and non-banking institutions.

We will continue to closely monitor further developments in this area and report on them in the future Legal News.