Blocking Bank Accounts in 2025: How the New Controls Work

In autumn 2025, thousands of Ukrainians unexpectedly lost access to their accounts and bank cards. Bank customers are reporting en masse: the account is suddenly blocked—without warning, calls from the bank, or clear reasons. The wave of blocks was triggered by National Bank of Ukraine (NBU) Resolution No. 65, which granted financial institutions maximum authority to monitor and analyze citizens’ transactions.

NBU Resolution No. 65 — how it works
This document, in force since 2020 but now particularly relevant due to martial law and economic turbulence, is based on the principle of risk-oriented financial monitoring. Each bank must:

• Analyze the client’s financial activity;
• Identify so-called anomalous, suspicious, or uncharacteristic-for-profile operations;
• At the slightest suspicion—request proof of funds sources, written explanations.

If requirements are not met, the account can be not just temporarily blocked, but forcibly closed, and the client’s data put on a “blacklist.”

How banks monitor clients
The financial monitoring system is fully automated: special algorithms analyze millions of transactions daily. Anomalous operations include:

• Sharp increases in receipts (change in income profile without explanation);
• Regular transfers from different people (especially small, frequent sums);
• Active cash withdrawals (if not consistent with declared client profile);
• Operations involving cryptocurrency or virtual assets (currently blocked or unregulated at NBU level);
• Transfers or incoming payments from prohibited jurisdictions.

A current innovation is the significant reduction of allowable limits on unsubstantiated transfers—even for “safe” clients (for example, the monthly limit may be 100,000 UAH).

What actually gets accounts blocked

• Client profile mismatch: if a student or pensioner receives large sums with no proof, the account may be blocked.
• Suspicion of unregistered business activity—frequent C2C transfers, goods sold via classifieds.
• Lack or insufficiency of documentation for large purchases/gifts/inheritance.
• Receiving or withdrawing funds from dubious or sanctioned sources.
• Ignoring or incomplete response to bank security service queries within financial monitoring.

Bank and client procedures

1. Card/account blocking can be automatic and without warning.
2. If the bank sees a suspicious transaction—it will send a request for income confirmation or an explanation.
3. If there is no exhaustive answer—the account stays blocked.
4. Client data may be added to the “blacklist” and forwarded to tax or law enforcement authorities or the NBU.

Often, for unblocking, clients must provide:

• Tax declarations;
• Statements from the place of work;
• Powers of attorney/gift deeds;
• Copies of receipts or other proof of funds origin.

Societal and business response
Lawyers and rights defenders state that the powerful filter blocks both potential schemes and entirely transparent transactions. Complaints are rising, and businesses disapprove that even private family transfers or declared freelance income may be blocked. Bank clients often face automatic denials and an inability to quickly regain access to funds.

Could the situation improve? Future outlook
A new “drops register” is being developed, which will include clients with suspicious activity patterns. This centralization will be part of a comprehensive AML/CFT policy, but also creates risks of mistaken blocking and the need for legal appeals. Banks have been given unprecedented independence in defining “risk” for swift action without government approval.

Tips for bank customers

• Declare sources of income in advance; keep profile data up to date.
• When possible, use separate accounts for business, family, freelance.
• Regularly keep documents confirming transfers (receipts, contracts, statements).
• Respond promptly to informational queries from the bank.
• Do not use dubious platforms or engage in currency transactions outside official accounts.

Conclusions
NBU Resolution No. 65 and strengthened internal bank rules in 2025 have made account blocking not the exception, but the new normal. Any suspicious transaction, anomalous money flow, or even mere inattentiveness to a client’s profile is now grounds for instant sanctions. For financial security, it is vital to know your own risk profile, communicate with your bank, and not neglect legal support if your account is blocked.

Author: Ihor Yasko, Managing Partner at WINNER Law Firm, Ph.D. of Law.
If you have questions or problems related to account blocking/unblocking or suspicious financial transaction investigations, bank payment refusals, dispute over returning funds, or issues with proving income legality or interaction with financial monitoring—contact the lawyers at WINNER Law Firm. Only qualified support can minimize risks and quickly restore access to funds in complex situations involving modern banking oversight.