Banks must keep electronic client questionnaires for safekeeping agreements

Published 20 July 2018. Some rules have changed since; ask us for the current position.

Banks must now complete an electronic client questionnaire when they sign an agreement for the safekeeping of a client's money or valuables. In letter No. 25-0008/37913 of 12 July 2018, the National Bank of Ukraine (NBU) explained how banks should compile and maintain electronic client questionnaires.

Failure to comply with Article 64 of the Law of Ukraine "On Banks and Banking" (Про банки і банківську діяльність) can have unpleasant consequences. That is why banks must identify and verify their clients. These measures are required by law and governed by anti-money laundering legislation. The system exists to prevent terrorist financing and the circulation of counterfeit money: before a client's account is opened, an agreement has to be signed and the financial transaction formalised.

Paragraph 67 of NBU Regulation No. 417 provides that electronic questionnaires must follow set standards and be kept for each client individually. A bank must complete a questionnaire when it signs an agreement for:

1. the storage of valuables or other property in an individual safe deposit box;
2. cash collection services and the transport of currency valuables;
3. money transfer services;
4. professional activity on the securities market, which is also flagged separately.

The electronic questionnaire must state the value and number of items kept in the client's individual safe deposit box.