The procedure for notification by financial institutions of discrepancies in the final beneficiaries has been regulated

The NBU Regulated the Procedure for Notifying Banks and Non-Banking Institutions of Discrepancies in Information on Ultimate Beneficial Owners and Client Ownership Structure.

The National Bank has regulated the procedure for informing banks and non-bank institutions about discrepancies between information on ultimate beneficial owners (hereinafter referred to as UBOs) and the ownership structure of a client (hereinafter referred to as discrepancies in UBOs and ownership structure) in accordance with current legal requirements by amending the relevant regulatory legal acts on financial monitoring.

Thus, banks and non-bank financial institutions must report discrepancies to the holder of the USR - the Ministry of Justice of Ukraine. Previously, such notifications were sent to the State Financial Monitoring Service.

In particular, the amendments provide for

• a deadline for a bank or non-bank financial institution to establish the presence/absence of discrepancies in the CBR and ownership structure;
• identification by a bank or non-bank financial institution of discrepancies and notification of their identification in accordance with the procedure established by the Ministry of Justice of Ukraine.

Banks and non-bank financial institutions will have a one-month transition period to bring their customer questionnaires, relevant customer lists and the register of discrepancies in line with the amendments.

The amendments were approved by Resolution of the Board of the National Bank of Ukraine No. 121 dated October 05, 2024 "On Approval of Amendments to Certain Regulatory Acts of the National Bank of Ukraine on Financial Monitoring", which comes into force on October 08, 2024 .

This Resolution amends the Regulation on Financial Monitoring by Banks, approved by Resolution of the Board of the National Bank of Ukraine No. 65 dated May 19, 2020 (as amended) and the Regulation on Financial Monitoring by Institutions, approved by Resolution of the Board of the National Bank of Ukraine No. 107 dated July 28, 2020 (as amended).