The Bank Sent a Financial Monitoring (фінмоніторинг) Request: What to Do and What You Definitely Shouldn’t Do

A notification from your bank requesting an explanation of financial transactions or the provision of documents is not a death sentence or a reason to panic. But it shouldn't be taken lightly either: the quality of your response often determines the fate of the specific transaction and your future banking relationship as a whole.

The main thing to understand from the very beginning is that the bank is not your adversary in this situation. It is acting within a legal framework that leaves it with little choice. And your task is to preserve your relationship with the bank, not to prove you're right. Closing an account and opening a new one at another bank is a tactical, forced move, not a smart strategy. This won't solve the problem, but it can gradually leave you without proper banking services altogether.

Here are 15 practical tips to help you get through the process without unnecessary losses.

1. Don't ignore the request

This seems obvious. But practice shows otherwise. Silence or delay is interpreted unequivocally by the bank: you have something to hide. Even if the response takes time, you should at least confirm receipt of the request and provide a timeline.

2. Don't start a conflict or appeal to your rights

Financial monitoring legislation is one-sided. It obligates the bank to check, suspect, and halt transactions, and it obligates the client to respond and provide documents. There are almost no rights a client can effectively rely on. The phrase "I pay all my taxes, what's the problem?" won't help in this situation. So, go through the procedure calmly. We are all hostages to these legal mechanisms.

3. Demonstrate openness and a willingness to engage in dialogue

A willingness to cooperate and respond without evasion is an indirect sign of the legality of your activities. If your bank allows you to contact a financial monitoring specialist directly, call or write to them personally before sending an official response. Clarify the details of the request, deadlines, and nuances. This isn't possible in all banks, but if the opportunity exists, you should take it.

4. Answer every single question

A formal brush-off or an attempt to "overlook" part of the request does more harm than good. Even if you have to disclose your pricing principles for goods or services, do it. An incomplete answer almost always generates an additional request, and with it, increased suspicion.

5. Carefully check documents before sending

Reread the entire package of documents carefully, and don't be too lazy to do it again. Gross inconsistencies are the most common reason for new requests. A classic example: the contract is dated before the bank account was opened, yet the account details are already listed in that contract. The bank sees things like this immediately. And explaining it away as a typo doesn't always work.

6. Don't respond to the bank the way you respond to the tax authorities

A template response like "we are located at our legal address, our business activity codes (KVEDy) correspond to our types of activity, thank you for your attention" doesn't work in financial monitoring. Data from the Unified State Register is available to the bank on its own in a matter of seconds. The bank isn't interested in the formal-legal side, but in the actual substance of your business.

7. Describe your business in your own words, not in the language of registries

If they ask about the nature of your business, explain what the business actually does. Without quoting registries and without legalistic constructions. Plain human language works better than official style in this situation.

8. Provide the real address

If they ask where you are physically located, you should name the real place: office, warehouse, production facility. If there is no lease agreement yet, tell the truth: the agreement is being negotiated, it will be signed around such-and-such a date, and you will provide it to the bank after signing. An honest answer is always better than one that will need to be clarified later.

9. Emphasize the economic logic of the transaction

The bank is not a tax authority. Even if a transaction has formal shortcomings from the point of view of the Tax Code, something else is important to the bank: whether the economic substance of what happened is clear. If the logic of the transaction is obvious and you can explain it, that's half the battle.

10. Check that the response is written in the first person

If a lawyer or an accountant prepares the response, make sure it hasn't turned into an impersonal legal text. If you received the request as a sole proprietor (FOP) or an individual, the phrasing should be "I, an individual entrepreneur...", "I, the client..." — not bureaucratic third-person constructions.

11. Don't deny the obvious

The bank, as a rule, already understands the typology of your transaction. It makes no sense to invent or distort facts. If a payment came into the account with the purpose listed as "for goods," you shouldn't write that it was actually help from relatives. Such contradictions are discovered immediately and undermine trust in the entire response.

12. Distinguish what is being asked of you

Explaining the origin of funds and explaining the purpose of their use are different in substance, and they should not be confused. If the bank asks you to confirm the origin of funds, then confirm the legality of the earnings. If the question is about a cash withdrawal or a transfer to a personal card, justify the need and purpose.

13. If business revenue went through your personal account, you should admit it

The excuse "I receive money on my personal card but record it in the income ledger" won't fly. It's better to honestly explain from whom and for what the funds were received, state your intention to file an annual personal income tax return and pay the taxes, and also note that in the future, the personal account will not be used for business. Unfortunately, this situation of using a personal card for business is a common reason for the bank to terminate its relationship with you.

14. If the bank asks you to update your questionnaire and asks about expected turnover, don't lowball the figure

The higher the limit you declare at the outset, the less likely the bank will question your usual incoming amounts. This isn't a trick, but realistic planning that protects you from unnecessary inquiries in the future.

15. As a last resort, you can file a complaint

If the bank is abusing the procedure and you are willing to wait, file a written complaint. In it, you should state that your next step will be to appeal to the NBU and file a lawsuit. You can demand the restoration of business relations, an explanation for the grounds for freezing the funds, or their immediate return. Judicial practice in such cases is predominantly on the client's side.

What else is important to remember

1. A bank's refusal to continue business relations is a last resort and means the client has been assigned an "unacceptably high risk" status. But even in this case, your money does not disappear anywhere.
2. Some clients, upon receiving a notice of termination, fear some consequences from the State Financial Monitoring Service (Derzhfinmonitorynh) or law enforcement agencies and simply forget about the balance in their account. This is a mistake. The bank is obligated to return your funds regardless of its reasons for terminating the relationship.