Droppers Registry and Restrictions on Suspicious Cards in 2025

In October 2025, the Verkhovna Rada registered draft law No. 14161 on creating and administering a so-called “drop register”—a database of individuals whose payment cards or accounts are used for suspicious transfers, transaction splitting, money laundering, and circulation of funds via opaque P2P transactions. This register is intended to become a key tool in combating financial “mules”, phishing schemes, cashing out limits, illegal online gambling, and countering the shadow economy.

What is a “drop” and why is it a problem
A drop (from the word “drop”—to hand off) is a bank cardholder who, for compensation, voluntarily gives their account, card, or e-wallet details to third parties or criminals. Use of drop cards enables one to:

• bypass bank limits and monitoring;
• repeatedly split transactions, masking their origin;
• launder “dirty” money—income from suspicious sources (shadow wages, online casinos, crypto exchange services, etc.);
• hide the beneficiary and avoid declaring real income.

According to the NBU, more than 200 billion UAH passes through drop cards in Ukraine each year—up to 15% of all P2P transfers; there are roughly 80–100,000 “new financial mules” in the country.

How will the drop register work
The National Bank of Ukraine will administer the register, and banks/payment providers will be obliged to identify suspicious customers, transmit their details to the database, and share risk metrics for anti-money laundering purposes.

• Those whose behavior, as defined by financial institutions, matches “mule” patterns (frequent P2P transfers to/from third parties, periodic large transactions without clear explanation, links to online gambling, etc.) will be listed in the register.
• Customers will be able to appeal their inclusion; details will be set out in a separate procedure.
• The explanatory note states registration does not automatically mean account freeze—the program protects even those whose cards were used by fraudsters without their consent.

What limits and penalties does the draft law introduce

• Significantly reduced available P2P transfer limits for drops.
• Ban on opening new accounts or cards for persons listed in the register.
• Enhanced financial monitoring of all transactions and higher risk scoring.
• Possible account suspension or proof of source of funds checks for especially risky transactions.
• For entrepreneurs—a higher bar for screening fake business activity.

Implications for banks, business, and citizens

• Banks get legal right to refuse to open accounts or cards for certain clients.
• Citizens risk investigations even from unintended use of their own card (e.g., if its details are stolen by fraudsters).
• Sole proprietors risk having business accounts blocked due to suspicious P2P activity.
• At the same time, the law gives a right to appeal register inclusion and prove innocence (details still under development).

International experience
Similar tools to fight “money mules” have long operated in the EU, USA, UK, and Canada. Maintaining “mule” registers helps uncover money laundering networks linked to cybercrime, fraud, and enables early-stage financial crime prevention.

Conclusion
The drop register is lawmakers’ response to challenges of the digital economy and the explosive growth of schemes using transit cards, P2P payments, online gambling, and proxy businesses. For Ukraine’s market, it will help protect the budget, fight abuse, and ensure greater transparency. Every bank card user should monitor their activity and boost financial security to avoid the “blacklist” risk. The law is meant to drive better financial monitoring and really shrink the gray sector in Ukraine.
Author – Yulia Popadyn, attorney specializing in tax and customs law at the “WINNER” Law Firm. If you have issues with account blocking/seizure, inclusion in the drop register, appeals of financial monitoring or bank sanctions, preparing complaints to the NBU or State Financial Monitoring, or legal defense strategies, consult our lawyers. Timely assistance will help you avoid serious consequences, restore account access, and minimize blacklisting risks—even in complex cases.