meta_id 3064125

On April 14, 2026, the National Bank of Ukraine (NBU) adopted a letter to banks in Ukraine regarding relations with politically exposed persons (PEP). Key points include: All clients who fall within the PEP category must be assigned a high-risk level or should be refused at the establishment of business relations. Banks must ensure the proper application of a risk-based approach when serving customers who are PEPs, with a view to establishing a reasonable level of risk for business relationships, preventing unjustified refusals, and continuing business relationships. Banks shall be held responsible for the improper application of the risk-based approach to PEP customers. If a PEP has ceased to perform prominent public functions, a bank is obliged to continue to take into account the customer's ongoing risks until it is satisfied that such risk no longer exists. If more than 12 months has passed since the PEP ceased to perform prominent public functions and the financial transactions demonstrate a low risk, financial monitoring does not have to be carried out.