When will the new financial monitoring rules for primary financial monitoring entities come into effect?

The Ministry of Finance has published a draft order “On Amendments to Certain Orders of the Ministry of Finance of Ukraine,” which proposes changing the effective date of Order No. 322 of 04 June 2021 “On Approval of the Procedure for Information Exchange on Financial Monitoring Matters.”

According to this draft, the Ministry of Finance’s Order No. 322 of 04 June 2021 “On Approval of the Procedure for Information Exchange on Financial Monitoring Matters” will enter into force on 1 December 2025. Additionally, on 18 November 2025, the Ministry of Finance published another draft order “On Amendments to Certain Orders of the Ministry of Finance of Ukraine,” according to which Order No. 322 of 04 June 2021 will enter into force on 2 February 2026.

What does Order No. 322 provide for?

The Cabinet of Ministers of Ukraine approved the Procedure for creating a personal account for a primary financial monitoring entity and for accessing the e-cabinet of the financial monitoring system.

The document was drafted with the aim of ensuring effective information exchange between primary financial monitoring entities and the State Financial Monitoring Service of Ukraine.

It provides for:

• the introduction of new types of notifications covering financial transactions subject to financial monitoring, as well as other information related to its implementation;
• the establishment of an obligation for PFME (primary financial monitoring entities) to apply a risk-based approach when conducting customer due diligence, which, in particular, involves transitioning to a case-based model of reporting suspicious financial transactions or activities;
• defining the procedure for submitting notifications on the freezing of assets related to terrorist activities, their financing, as well as the proliferation of weapons of mass destruction and its financing.

The e-cabinet will function as an element of the unified information system in the field of preventing and combating money laundering, terrorist financing, and the proliferation of weapons of mass destruction. The key provisions include:

• The creation of a personal account is carried out based on the identification data of the primary financial monitoring entity and its qualified electronic signature.
• Access to the restricted part of the e-cabinet is granted only after electronic identification.
• Through the e-cabinet, entities will be able to submit notifications required by legislation in the field of financial monitoring, as well as receive requests, instructions, and decisions from the State Financial Monitoring Service.
• The e-cabinet operates around the clock (except during maintenance periods) using a comprehensive information security system.
• In case of technical issues, a procedure for notifying and promptly resolving such failures is provided.