Monobank blocks accounts “arbitrarily”: NBU fined Universal Bank for violating financial monitoring rules

The National Bank of Ukraine in 2025 applied sanctions to JSC “Universal Bank,” the legal entity that services monobank’s customers, including a fine of 27,3 million UAH in October. The total amount of the bank’s fines for the year was estimated in publications at 70,4 million UAH. At the same time, customers complain about account blockings and termination of service even after providing documents proving the source of funds. The bank is linked to the business group of Serhiy Tihipko, while the monobank technology platform is developed by a separate company — Fintech Bend LLC.

According to figures cited in publications about the banking sector’s operations, during 2025 the National Bank received 60 926 customer complaints about banks. Of these, 6423 concerned account blockings or seizures. Such restrictions can be applied after regular transfers between cards, cryptocurrency transactions, receipts that do not match declared income, or other atypical movements of funds, media report. In cases complained about by monobank customers, the bank may request income statements, tax returns, contracts, or other documents to confirm the source of funds. However, users report that even after submitting documents the account sometimes remains blocked or the bank notifies them of termination of the business relationship. As the legal basis for such decisions, financial institutions may cite Article 15 of Law No. 361-IX on preventing legalization of proceeds from crime and financing of terrorism. Legally, monobank customers’ bank accounts are serviced by JSC “Universal Bank” (EDRPOU 21133352). This institution holds the banking license and is responsible for complying with financial monitoring requirements, conducting transactions, and maintaining banking secrecy. Serhiy Tihipko is associated with the business group that owns the bank. At the same time, monobank’s technological infrastructure and digital services are provided by Fintech Bend LLC (EDRPOU 32388371). Among Fintech Bend’s owners listed in the cited data are Oleh Horokhovskyi, Mykhailo Rohalskyi, Yevheniia Kryvenko, Darya Bukreeieva, and the Cyprus company Crestline Limited. This division of roles matters for determining responsibility for servicing customers: the technology platform and the licensed bank are separate legal entities, and decisions regarding bank accounts are made within the bank’s activities. In October 2025 the NBU fined Universal Bank 27,3 million UAH for violating financial monitoring requirements. The total amount of fines imposed on the institution during the year, according to publications, was 70,4 million UAH. In addition, the regulator issued written warnings. Among the problems noted during supervision were shortcomings in customer verification procedures and risk management. At the same time, the regulator’s fines by themselves do not confirm the legitimacy or illegitimacy of each individual account blocking.

After the state limit of 150 thousand UAH on card-to-card transfers was lifted, banks continued to apply restrictions provided by the memorandum on transparency of the payment services market. For high-risk customers without confirmed income a monthly limit of 50 thousand UAH was set, and for medium- and low-risk customers — 100 thousand UAH. Restrictions can also apply to individual IBAN transfers. The memorandum was signed by banks voluntarily, so it is not an NBU normative act. Specific requirements for risk assessment are set out in NBU Resolution No. 65 of 19 May 2020. Its paragraph 37 provides that unjustified de-risking — terminating relations with a client solely to remove risk without a proper individual assessment — is unacceptable. According to the cited data, the National Bank additionally emphasized this position on 6 February 2024. At the same time, financial monitoring legislation allows banks to refuse service for grounds specified by law, and disclosure to clients of certain details of checks may be limited. Disputes over termination of banking services are also considered by courts. Examples cited include cases No. 910/11103/23, No. 759/1627/25-ts and No. 910/10855/24. Simply invoking financial monitoring requirements does not remove the need to comply with the law and properly assess the risk of a specific client. At the same time, the circumstances of each dispute depend on the documents, the grounds for blocking, and the facts established by the court. In the summer of 2026 NBU Chairman Andrii Pyshnyi drew attention to the specifics of monobank’s organization: Oleh Horokhovskyi is not part of Universal Bank’s management, and the technology company is not under the same banking supervision as the licensed institution. Responsibility for compliance with banking requirements, however, remains within the supervision of the bank itself. New rules on third-party risk management, according to the cited data, are fixed in NBU Resolution No. 70 of 30 June 2026. Customers who disagree with an account blocking or closure can request a written explanation of the decision to the extent permitted by law, file a complaint with the National Bank, or challenge the institution’s actions in court. The outcome of a review depends on the specific grounds for the restrictions applied, the documents provided, and the bank’s compliance with financial monitoring requirements.