### 1. Substance of the Resolution<\/p>\n
This Resolution of the National Bank of Ukraine No. 56 dated May 27, 2026 is aimed at significantly improving and detailing supervisory procedures in the areas of financial monitoring, currency control, and the application of sanctions. The document introduces clear rules for conducting unscheduled on-site inspections of currency exchange offices, in particular through the execution of “test transactions.” It also establishes a legal mechanism for banks to appeal the “professional judgment” of NBU inspectors through a specialized Committee of the regulator. Separately, it regulates safety issues and the procedure for inspection teams during air raid alerts under martial law conditions.<\/p>\n
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### 2. Structure of the Resolution, Main Provisions, and Amendments<\/p>\n
The Resolution has a comprehensive structure and amends several core regulatory acts of the NBU:<\/p>\n
* **Amendments to Regulation No. 90 (organization and implementation of supervision):**
\n * *Risk assessment:* A periodic (quarterly) risk assessment of the use of banks\/institutions for the laundering of illicit funds has been introduced, which will directly affect the frequency of inspections.
\n * *Professional judgment:* The NBU is granted the right to state its professional judgment in inspection certificates\/reports, and the procedure for financial institutions to appeal such judgment to the NBU Committee is detailed.
\n * *New Section VIII:* Entirely dedicated to unscheduled inspections of structural units (currency exchange offices) regarding compliance with the rules of cash foreign exchange transactions.
\n* **Amendments to Regulation No. 106 (corrective measures):**
\n * The adoption of procedural decisions (in particular, regarding the recusal of members of the Board or the Committee of the NBU) has been regulated.
\n * The procedure for publishing decisions on corrective measures on the NBU website, in cases where the location of the institution cannot be established, has been defined.
\n* **Amendments to Regulation No. 153 (supervision under martial law):**
\n * A detailed algorithm of actions for the inspection team and employees of institutions in the event of an air raid alert (threat of emergencies) has been added.
\n* **Amendments to Resolution No. 165:**
\n * Paragraphs 7\u201328, which previously regulated the specifics of cash foreign currency trading during martial law, have been excluded, and the nature of unscheduled inspections has been clarified (exclusively “on-site”).
\n* **Reporting updates (Annexes 1 and 2):**
\n * The forms for submitting information on customers, updating their data, as well as payment transaction parameters (including unique card numbers (PAN), IP addresses, terminal IDs, etc.) have been modified and detailed.<\/p>\n
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### 3. Main Provisions Important for Practical Use<\/p>\n
For the practical activities of financial institutions, the following innovations are the most critical:<\/p>\n
* **Mechanism for appealing “professional judgment”:** Institutions have been granted the right, within 15 business days from the date of receipt of the inspection report, to apply to the NBU for a review of the professional judgment stated therein. The NBU Committee must consider such an application within 90 calendar days. At the same time, the inspection report itself is not annulled even if the application is approved.
\n* **Test foreign exchange transactions (analogous to a “test purchase”):** NBU inspectors have the right to conduct a test foreign exchange transaction before presenting the inspection order. After the transaction is completed and the order is presented, the cashier of the currency exchange office is obliged to perform a reversal (storno) transaction and return the cash to the inspectors within 15 minutes.
\n* **Counteracting the obstruction of inspections:** Failure to provide documents, access to automation systems, or the video archive (a copy of the video archive segment must be provided within 1 hour of the request) is qualified as a refusal to conduct the inspection. In this case, an “act of refusal” is drawn up, which serves as a ground for the application of severe corrective measures.
\n* **Algorithm of actions during an air raid alert:** In the event of an alert signal, the inspection is immediately suspended, and the inspectors leave the premises. Work must be resumed within 30 minutes after the all-clear signal (if the institution’s operating hours permit). If less than 30 minutes remain before the institution closes after the all-clear signal, the inspection is terminated early, and a corresponding report is drawn up.
\n* **Transitional period for automation:** Financial institutions are granted a period of **6 calendar months** (starting from the month following the month in which this Resolution enters into force) to configure and automate the generation of new standard forms of responses to NBU requests (in accordance with updated Annexes 1 and 2).<\/p>\n