---
title: "NBU tightens control: how 'structuring' of transactions and phone transfers came under the regulator's scrutiny"
description: "🚨 The NBU has tightened control over currency exchange. The regulator identified schemes involving 'structuring' of transactions and phone transfers to bypass limits. Banks are advised to actively use video surveillance and analyze the behavior of groups of individuals. Read the details about the new monitoring rules."
date: 2026-08-13T04:34:00.000Z
lang: en
url: https://xab.info/en/posts/nbu-tightens-control-currency-operations-structuring-en
tags: [nbu, currency-exchange, financial-monitoring, ukraine-economy, banking-regulations]
publisher: "XAB.info"
---

# NBU tightens control: how 'structuring' of transactions and phone transfers came under the regulator's scrutiny

![Man at currency exchange window with sign 'Обмін валют' — visual for news on NBU tightening control over currency transactions, including transaction splitting](https://xab.info/media/2026/08/13/nbu-uzhestochaet-kontrol-valyutnye-operacii-droblenie/nbu-uzhestochaet-kontrol-valyutnye-operacii-droblenie-1.webp)

## 🎯 Key Points

- The NBU identified cases of structuring currency operations to bypass limits.
- Banks are advised to analyze client behavior in aggregate, not just by individual transactions.
- Phone transfers and attempts to conceal appearance are recognized as risk indicators.
- The regulator requires banks to fully provide video recordings from branches.

The National Bank of Ukraine (NBU) has intensified supervision over currency exchange operations, focusing on new schemes to evade financial monitoring. During inspections, the regulator identified cases where clients intentionally split their transactions or involve third parties to bypass legal requirements. Given the current economic situation and the need to combat capital outflow, the NBU has urged banks to move from formal control to a deep analysis of client behavior.

### The 'structuring' scheme: how limits are bypassed

One of the key risk indicators highlighted by the regulator is so-called transaction structuring. The essence of this method lies in splitting one large transaction into several smaller ones, each not exceeding the threshold for mandatory declaration. Specifically, the NBU recorded cases of multiple transactions of up to 400,000 hryvnias in equivalent within a short period. This tactic allows clients to avoid heightened attention from bank security services, which traditionally focus on large transactions.

### Network nature of operations and hidden connections

The regulator emphasizes that banks must analyze not only the size of an individual transaction but also the aggregate actions of a client. Another alarming signal is the distribution of transactions among several related individuals. If a group of people, who are not relatives, conducts exchange operations in the same branch or at different points of the bank's network at the same time, this is viewed as an attempt to conceal the true origin of funds or their ultimate beneficiary. Banks are advised to monitor such behavioral patterns in real-time.

### Physical signs: phone transfers and disguise

The NBU also highlighted a number of physical circumstances that may indicate a suspicious nature of the operation. These include the transfer of cash, phones, or other items between clients directly at the moment of the transaction. Additionally, attempts to conceal one's appearance — for example, using hoods, masks, or sunglasses indoors — have been added to the list of 'red flags.' It is important to note that the presence of one of these signs is not an automatic ground for initiating a case, but it obliges the bank to conduct an in-depth check within the framework of financial monitoring.

### Video surveillance as a tool for evidence

The regulator paid special attention to the role of video recordings from bank branches. According to the NBU, surveillance camera recordings are what allow for the establishment of the true circumstances of the operation, tracking the movement of cash, and verifying the actual behavior of clients against data in documents. However, inspections revealed cases where banks did not provide video recordings upon NBU requests or provided them only partially. In this regard, the regulator strongly recommended that banks strengthen internal control, regularly review archives, and monitor tellers' work to exclude such omissions.

## 🔍 Fact-Check Verification

- [Owners of currency OVGZ will not be able to sell them due to current NBU regulation — NCSSF](https://minfin.com.ua/2025/05/30/151867866/) - Подтверждено по источнику minfin.com.ua

## ❓ FAQ

### Q: What is structuring of currency operations?
**A:** This is the division of one large transaction into several smaller ones (e.g., up to 400,000 UAH) to avoid mandatory declaration and heightened control by the bank.

### Q: Can transferring a phone become a reason for refusal of exchange?
**A:** The transfer of a phone itself is not a ground for refusal, but it is one of the risk indicators that obliges the bank to conduct an additional check of the client.

### Q: Why does the NBU require video recordings?
**A:** Video recordings allow the regulator and banks to establish the real circumstances of the transaction, verify the movement of cash, and identify attempts to conceal identity or connections between clients.