Restrictions on card transfers have been imposed since October 1

The temporary limit on the amount of card-to-card transfers will prevent the use of payment infrastructure for illegal purposes and will not affect the activities of volunteers.

Starting from October 1, 2024, the National Bank will temporarily set a limit of UAH 150,000 per month for card-to-card transfers (also known as P2P, C2C) for six months.

The limit applies only to outgoing transfers across all accounts of a client opened in one bank to accounts of other individuals.

The limit does not apply to the accounts of volunteers who meet the criteria set forth in the resolution and individuals whose monthly income from verified sources exceeds the amount of the limit. It also applies to transfers of funds between the client's own accounts opened with the same bank and to transfers of legal entities. Transactions using IBAN details are not limited.

According to the NBU, 98% of bank customers make monthly transfers that do not exceed this amount, so the restrictions will not affect their financial activity in any way.

Why does theproblem of "drops" require a quick response?

"Drops" are people who transfer their card account details and data to third parties for payment. These accounts are used as "transit" accounts for transferring and laundering illegal funds. It is difficult to estimate the scale of the problem of using "drops" because they imitate the usual behavior of an individual, but in general, the system is talking about tens of thousands of "dormant" and active accounts.

According to several major banks, in 2024, business relations with more than 80,000 customers have already been terminated due to participation in drop schemes. The amount and number of card-to-card transfers show a steady upward trend in all groups of banks, regardless of the volume of card business.

The NBU's analysis shows that about UAH 200 billion a year can be transferred through drop cards.

The shadow business is looking for new ways to make money payments, and this requires a quick response, so the NBU is introducing the limit as a temporary, anti-crisis solution.

What is the main goal of the innovation?

The introduced limit will help minimize the use of payment infrastructure in illegal activities, in particular through the use of drop accounts, which are a common mechanism for the shadow economy.

Some payment market participants are already implementing effective rules, indicators, and transaction analysis models to identify atypical customer payment behavior, but these practices should be mandatory for the entire payment market.

At the same time, the problem is not only urgent, but also complex and requires amendments to legislation and the involvement of other government agencies, including law enforcement agencies, to interact within their powers. The six-month restriction period will be used to develop joint solutions to address this problem. This will allow the National Bank of Ukraine to abandon the introduced limits in the future, provided that the measures taken are effective.

What are the next steps planned to combat the misuse of the payment services market?

First, the adoption of Draft Law No. 11043, which provides for an increase in the amount of fines for violators of payment legislation and ensures conditions for the prompt exchange of data with the Cyber Police.

Second, the introduction of legal provisions to bring to justice the organizers and conscious participants of illegal schemes.

Thirdly, the creation of a relevant register that will become a source of information for banks when establishing business relations and servicing customers whose cards have been used in illegal schemes. Rules will be developed according to which the information will be submitted to the register and further used by market participants.

Fourth, amendments to the payment legislation that will expand the NBU's regulatory powers to apply penalties and restrictions to market players that do not effectively combat existing and new schemes.

Fifthly, the NBU will tighten requirements for banks and non-bank institutions to strictly comply with legal requirements and establish efficient operation of their own automated systems, as well as create indicators, rules, and models for detecting atypical customer behavior. As well as improving the efficiency of risk management systems and internal control systems in accordance with the NBU's requirements and recommendations.

Can the limits affect the fees paid by volunteers?

No, the established limits will not affect the activities of volunteers. To make sure of this, the NBU held several discussions with the volunteer community. Based on their results, the decision was calibrated and contains a corresponding warning that the limits will not apply:

• when replenishing the accounts of individuals engaged in volunteer activities and identified by banks/payment service providers as volunteers;
• when transferring funds from the accounts of individuals engaged in volunteer activities and identified by banks/payment service providers as volunteers.

The Resolution defines five criteria for volunteer activities. In order for payment service providers to identify an individual who plans to engage in volunteer activities as a volunteer, he or she must meet at least two of the five criteria.

The relevant amendments were introduced by Resolution of the Board of the National Bank of Ukraine No. 102 "On Amendments to Resolution of the Board of the National Bank of Ukraine No. 18 of February 24, 2022" dated August 27, 2024. They will come into force on August 28, 2024. The amendments apply to all payment service providers.