Implementation of the 'Money Mules' Register

October 29, 2025 Draft Law No. 14161 has been registered in the Verkhovna Rada on amendments to certain laws of Ukraine concerning the creation and maintenance of a register of persons whose payment transactions require enhanced monitoring.

The main goal of the Draft Law is to establish a legal mechanism for accumulating, storing, and exchanging information about individuals whose payment transactions require enhanced control, with the aim of preventing the illegal use of payment infrastructure.

The Draft Law is aimed at counteracting the use of payment instruments in illegal schemes, particularly in the sphere of gambling, betting activities, and the sale of excise goods. A significant amount of funds currently passes through the system of money mules (individuals who provide their bank account details to criminals). Money mules are increasingly being used by outright criminals: from call centers to narcotics trafficking.

The key provisions of the Draft Law define the legal framework for the functioning of the Register of such persons, which will be created and maintained by the National Bank of Ukraine (NBU). Payment service providers will be obligated to enter information into the Register about users — individuals and merchants — in whose actions signs of illegal use of payment instruments are detected. Signs of illegality include the transfer of the right to dispose of funds/payment instruments to a third party, or signs of accepting electronic payment means for paying the cost of goods or services with violation of established requirements.

Payment service providers will be required to regularly check the presence of their clients in the Register, specifically:

• before establishing business relationships with a user-individual or merchant;
• upon changing user or merchant data;
• during authentication in remote communication means (including re-registration with a periodicity determined by the NBU);
• upon logging into a payment application from a new device;
• in the event of detecting established signs during payment monitoring;
• upon each change/addition of a new merchant category code.

In the event of information about the user being present in the Register, payment service providers will be obliged to apply NBU-established limits on conducting payment transactions to users. For individuals, restrictions on the number of payment instruments and/or accounts opened with a single payment service provider will be applied. Limits on conducting payment transactions, including on the volumes of acquiring operations, will be applied to merchants. Should the established limit on the number of accounts be exceeded, the provider will refuse to open a new account.

The changes are aimed at enhancing the transparency and effectiveness of state control in the payment services sector, establishing clear control procedures for the circulation of funds, and ensuring stable and predictable conditions for legal business.

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