Banks are increasingly blocking the accounts of Ukrainians due to indicator words in payment documents: advice from lawyers on avoiding blocking

Lawyers regarding the blocking of bank accounts due to keywords in the purpose of payment

From October 1, the National Bank of Ukraine, in the context of the expansion of Open Banking technology, introduced several significant changes to the transparency of each money transfer transaction. Therefore, citizens of Ukraine should be prepared for banks’ close attention to bank transactions, especially to the content of the purpose of payment. Andrii Shabelnikov, managing partner of the legal association EvrikaLaw, head of the committee of the National Association of Lawyers on Investment Activities and Privatization, informed the Informant about this.

The lawyer recalled that in October 2024, the NBU, together with leading banks, concluded a memorandum on the openness of the payment services market. He established a new three-level control system. If your transactions do not exceed 30 thousand hryvnias per month, you are actually in a safe zone, and the bank usually does not ask additional questions. If we are talking about amounts from 30 to 400 thousand hryvnias, the bank can initiate an additional check – especially if the transactions look unusual for your profile.

“All payments exceeding 400,000 are automatically subject to mandatory control, in which case the client will need to provide documents confirming the legality of the origin of the funds. In addition, as of October 1, as part of the development of Open Banking technology, the National Bank implemented a number of important changes regarding the openness of each fund transfer transaction. Therefore, Ukrainians should be prepared for banks’ close attention to bank transactions, especially to the content of the purpose of the payment,” noted Shabelnikov.

Sequence of actions to avoid blocking due to “trigger words” Lawyer Ihor Tarasenko recommends determining the nature of the payment

• Goods or services → pay to the account of the FOP or company.
• Private transfers (family allowance, gift) → personal account.
• Debt repayment → only with written confirmation of the receipt, and preferably the loan agreement.
• Cryptocurrency → prepare proof of origin of money (KYC of the exchange, transaction history).

It is important to be aware of the correctness of the account, i.e. financial transactions – not on personal cards. Regular receipts to a personal account without FOP status are a risk. Make a secure payment destination. Avoid transfers to a personal card indicating payment: “for cryptocurrency”, “currency exchange”, “salary”, “for goods or services”. Apply in the purpose of payment: payment to account No.___ from, contract No.___; repayment of the loan under contract No.___ from ___; private transfer or gift without VAT; transfer of personal funds between your accounts. Always include the document number and date.

“Call things by their names, but in the language of documents, not “slang”. Financial transactions — only through financial accounts; provide any “non-standard” payment with evidence of the origin of the money,” advises Tarasenko.

According to the managing partner of Hanna Ishchenko and Partners JSC, Hanna Ishchenko, the expression “For goods/services” on a personal account is an obvious trigger. The bank suspects that you are carrying out business activities without registration of a business entity and payment of taxes. Words “For the crypt” or “Currency exchange” indicate operations related to unregulated or shadow financial markets, which is very dangerous for the bank. Regular transfers with a destination “Debt repayment” may hide systematic income from entrepreneurship or other activities that must be declared.

How the blocking mechanism works (why is it blocked after payment) Banks use automated financial monitoring systems that work according to the principle analysis of the totality of operations (retrospective analysis), not instant control. Making payment: One or more questionable payments may pass because they do not exceed the instant limits. Risk escalation: The system continuously accumulates “risk points” by analyzing:

• Number of operations: Frequent receipts from many different people (this is a clear sign of running a business).
• Amount and Regularity: A sharp increase in turnover that does not correspond to the declared profile of the client.
• Purpose of payments: Systematic use of keywords.
• Triggering of the limit: When the risk level reaches an internal threshold, the system automatically blocks account to prevent further risky transactions. Demand from the client documentary explanations about the source of the money.

If the account is blocked, the bank will demand documentary confirmation of the legality of the funds and economic feasibility of operations. Documents certifying the source of money:

• Official income: Certificate from the place of work about income for the last period, tax declaration.
• Income from the sale of property: Notarized sales contract (apartment, car).
• Inheritance or gift: Inheritance certificate or notarized donation agreement.
• FOP income: Tax declarations, agreements with counterparties and tax receipts.
• Explanation: Provide a written explanation detailing the nature of your transactions.

Actions in case of unjustified bank refusal:

• Complaint to the NBU: File a formal complaint with National Bank of Ukraine (NBU). Attach copies of all your documents and the bank’s written refusal (if available). The NBU may require the bank to reconsider the decision.
• Judicial Protection: If the NBU was unable to resolve the issue, contact court. This is the only way to forcefully unblock the account and recover damages. For this, it is worth involving a qualified lawyer.

“Although it may be uncomfortable, monitoring encourages citizens who actually run a business to legalize their activities (regulate FOP). This provides them with a pension, official confirmation of income for loans or visas, as well as legal protection. Ultimately, it contributes to increasing tax transparency in the state, which is extremely important for filling the state budget and ensuring social programs. Thus, despite temporary inconveniences, increased control is a necessary element of functioning modern, safe and transparent financial system”, Ishchenko stressed.

Banks massively began to block accounts because of the words-t riggers in the purpose of payment Earlier in some mass media there was information that financial organizations are increasingly responding to so-called trigger words when assigning a transfer. Even ordinary transactions may come under suspicion if the wording seems risky to the bank. Potentially “dangerous” phrases:

• “for the crypt”;
• “Currency exchange”;
• “for goods/services” — if the funds are received not on the FOP account, but on a private one;
• “debt repayment” — if such transfers are regular.

The source