In 2024, the National Bank plans to inspect 4 objects in the payment market as part of on-site oversite monitoring (supervision) – 2 banks and 2 non-bank institutions. The NBU reported this in response to an official request from the Ministry of Finance.
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The regulator clarified that due to the start of full-scale military aggression of the Russian Federation in 2022, as well as due to the 9-month adaptation period established by the new legislation for objects of supervision, oversite activities were resumed from May 2023.
National Bank clarified the chronology of previous inspections:
• 2021 – on-site monitoring of 6 objects was carried out (1 bank, 5 non-banking institutions), based on the results, measures were applied to 5 – written warnings.
• 2022 – on-site monitoring was not carried out due to the introduction of martial law, but 2 written warnings were issued based on the results of monitoring in 2021.
• 2023 – on-site monitoring was resumed and carried out in relation to 5 objects of supervision (1 bank, 4 non-banking institutions), and one written warning was issued.
“During 2021–2022, fines based on the results of on-site monitoring were not applied to oversite objects, since they were not provided for by the law “On payment systems and transfer of funds in Ukraine” (lost force) and the regulations of the NBU. The application of enforcement measures in the form of a fine based on the results of monitoring oversite objects has become possible since May 2023 after the NBU adopted the relevant regulations, in accordance with the law “On Payment Services” that was put into effect, the National Bank explained to the Ministry of Finance.
< p>The National Bank named the most common violations identified during on-site monitoring:
1. Providing unreliable statistical reporting data (violation of the procedure for generating indicators and parameters of statistical reporting) about the activities of payment systems and their participants, the presentation of which is provided for by the regulations of the NBU.
2. Providing services in violation of the requirements of the rules agreed with the National Bank.
3. Violation of requirements for ensuring business continuity and information protection.
4. Failure to comply with the requirements of Ukrainian legislation in the field of intellectual property when using software on all components of the software and hardware complex.
