Strengthening financial monitoring and the account register: new requirements for businesses

In 2025, Ukraine continues to reform its financial monitoring system by expanding mechanisms for controlling financial transactions and introducing new tools to increase economic transparency.
One of the most important recent initiatives has been the launch and active use of the Accounts Register, an electronic database containing information on all bank accounts held by individuals and legal entities.

The role of financial monitoring for the economy
Financial monitoring is a set of measures aimed at detecting and preventing the laundering of proceeds of crime and the financing of terrorism.
The main authority responsible for this activity in Ukraine is the State Financial Monitoring Service.
In recent years, the scope of financial monitoring has significantly expanded: it now covers banks, non‑bank financial institutions, payment systems, leasing companies, stock exchanges, real estate agencies, notaries and other business entities.

The primary goal of financial monitoring is to ensure transparency of financial flows, strengthen confidence in the Ukrainian financial system and achieve compliance with international standards, in particular the recommendations of the Financial Action Task Force (FATF).
Compliance with these standards is a key step for attracting foreign investment and integrating Ukraine into the global economy.

Accounts Register: essence and purpose
The Accounts Register is an electronic database containing information on all bank accounts opened in Ukraine.
It includes data on account holders, account details, dates of opening and closing, as well as information about the issuing banks.
The Register has been created in order to:

• provide law enforcement bodies, courts and other authorised entities with prompt access to information on financial accounts;
• increase the effectiveness of criminal investigations, in particular those related to money laundering, tax evasion and fraud;
• monitor suspicious transactions and detect schemes aimed at hiding assets or evading financial obligations.

State authorities, courts, the State Financial Monitoring Service, tax authorities, law‑enforcement agencies and certain obliged entities performing financial monitoring functions have access to the Accounts Register.
At the same time, access to the data is restricted and governed by personal data protection legislation.

New requirements and obligations for business
The introduction of the Accounts Register and the tightening of financial monitoring requirements have a significant impact on business.
Entrepreneurs and financial institutions are forced to review their internal procedures, implement new control mechanisms for financial transactions and improve the level of documentation and reporting.

The main new obligations for businesses include:

• mandatory provision of comprehensive information on account holders, including beneficial owners;
• continuous monitoring of transactions for signs of suspicious activity;
• prompt responses to requests from the State Financial Monitoring Service and other supervisory authorities;
• implementation of internal control systems capable of detecting and blocking suspicious operations;
• strict compliance with document‑retention and personal‑data protection requirements.

For businesses, this means increased administrative burdens, the need to invest in IT infrastructure and enhanced staff training.
However, these measures help build trust in Ukrainian companies among foreign partners and clients.

Challenges for entrepreneurs
Despite the positive effects, the new financial monitoring mechanisms pose several challenges for business:

• Higher risks of account blocking. Banks are becoming more cautious, and any suspicious transaction may result in temporary blocking of an account, which is especially problematic for companies working with large volumes or complex ownership structures.
• Lack of clear guidance. Detailed methodological recommendations on how to identify suspicious transactions are not always available, which leads to subjective interpretations by banks.
• Personal data protection. Use of the Accounts Register raises concerns about the security of confidential information and the risk of unauthorised access or data leaks.
• Additional costs. Implementing financial monitoring systems, training staff, conducting audits and preparing reports require extra financial and time resources.

International experience and outlook
In many European countries, the United States and other developed jurisdictions, account registers and financial monitoring systems have long been integral parts of the financial infrastructure.
These mechanisms make it possible to effectively combat money laundering, terrorist financing and other financial crimes.
For example, Germany, France and Italy operate centralised databases of bank accounts that law‑enforcement bodies can access under certain conditions.

In Ukraine, the introduction of the Accounts Register and stricter financial monitoring is a step towards integration with the international financial system.
For this initiative to succeed, it is necessary to:

• ensure transparent and clear rules;
• guarantee protection of personal data and prevent abuses;
• provide businesses with clear methodological guidance and support;
• continuously update legislation in line with international standards and the real needs of the Ukrainian economy.

Impact on the tax system and tackling evasion
The Accounts Register enables tax authorities to quickly obtain information on cash flows, uncover income‑concealment schemes and track suspicious transactions.
This creates additional risks for those attempting to evade their tax obligations.

At the same time, honest entrepreneurs benefit from a more level playing field, as tax evasion becomes harder to hide.
Growing confidence in the tax system contributes to higher tax revenues and greater stability of the state budget.

Future development
In the future, the functions of the Accounts Register are expected to expand further, including integration with other state registers (such as the beneficial owners register and the register of legal entities) and the use of modern artificial‑intelligence technologies to analyse financial flows.
International cooperation in the field of financial monitoring and information exchange between Ukraine and other countries is also expected to intensify, helping to combat cross‑border financial crime more effectively.

Conclusions
The introduction of the Accounts Register and the strengthening of financial monitoring constitute an important step in combating money laundering, terrorist financing and other financial offences.
For businesses, this means greater transparency but also higher administrative costs and risks.

Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law.

If you have any questions or face issues related to financial monitoring, the Accounts Register, account blocking or other aspects of fiscal control, you can contact the experts at WINNER Law Firm.
They will help you analyse the situation, prepare the necessary documents and protect your interests in dealings with banks and supervisory authorities.