The Logic Behind the NBU's Financial Monitoring: A Cover-Up for Sens Bank and Record Fines for EasyPay and City24

The National Bank of Ukraine has once again imposed a multi-million fine on a financial market participant. On September 2, the NBU fined the Ukrainian online platform iPay 16.5 million UAH and issued a written warning to the company due to violations of payment requirements. The iPay platform must pay the fine within a short timeframe—within five business days from the date it was notified of the NBU Committee’s decision.

These actions are fully in line with the NBU’s stated tough policy of cracking down on gray-market schemes and complying with the requirements of international donors. However, against the backdrop of numerous corruption scandals, such as “Midas” and “Forest Gump,” more and more questions are being raised about the objectivity of the actions of the National Bank itself and its chairman, Andriy Pyshnyy.

According to media reports, the decisions to impose exorbitant fines do not always appear justified or logical. In some cases, the fines are so substantial that they exceed the profits of a given institution. Moreover, the media scandals they trigger also cause reputational damage to companies. Thus, overall, this practice may appear to be systematic economic pressure on individual market participants.

For more details, see the UA.News article.

A
Wave of Record Fines
 

Since the beginning of the year, the National Bank of Ukraine has imposed record fines totaling several million hryvnias on a number of non-bank financial institutions, with the total amount exceeding 374 million hryvnias. In total, there have been 54 instances of companies being fined, with some market participants receiving repeated sanctions.

Among those penalized were well-known leading payment platforms, major insurance companies, and “Ukrposhta.” The NBU was undeterred even as large-scale scandals erupted over some of its sanctions and personnel decisions. It even escalated to a personal media confrontation, as in the case of “Ukrposhta,” whose CEO, Ihor Smilianskyi, alleged pressure from NBU leadership and an attempt to block the creation of Ukrposhta Bank.

Statistics show that the largest fines were imposed in May—approximately 331.5 million UAH. The bulk of these fines were directed against the companies “Kontraktovy Dom,” “Swift Garant,” and VUSO.

Following the May inspections, the two largest payment terminal networks—EasyPay (FC “Kontraktovy Dom” LLC) and City24 (Swift Garant LLC)—received massive fines: 135 million hryvnias each. The NBU cited violations of financial monitoring laws as the official reason. Simply put, the National Bank believes that the companies failed to properly verify the origin of the money passing through their terminals. However, the details of these allegations raised questions in the media and led to speculation that the high-profile statements about the “fight against dirty cash” involving 270 million hryvnias might be part of a larger administrative and media strategy.

The NBU’s
Harsh Sanctions and a Departure from Routine Oversight
 

Before the fines were announced, the press actively circulated information alleging that these terminal networks were linked to businessman Timur Mindich and the high-profile “Midas” case. However, the actual facts indicate that there is most likely no legal or financial connection between EasyPay, City24, and the individuals implicated in the investigations.

Both companies—EasyPay and City24—are completely transparent and have in no way been observed collaborating with companies implicated in the “Midas” case. At the same time, the argument that a certain debt collection firm once rented an office in the same building where Mindich’s factory is located seems flimsy. In a big city, neighbors in the same office complex are hardly likely to be criminal accomplices. Often, such addresses are used simply as mailboxes.

Neither company is a party to the criminal cases involving this businessman, and the regulator has not provided clear evidence of their illegal coordination.

A fine of 135 million for a non-banking company is effectively an attempt to cripple the business. At the same time, according to financial analysts, the National Bank’s claims appear ambiguous and contain several obvious technical manipulations.

Shifting the blame: The NBU accuses the terminals of failing to properly identify people. But a terminal is simply a metal box for depositing money. Most transactions there involve card reloads (for Monobank or PrivatBank, for example). When a person deposits funds, they enter their phone number, receive an SMS or a call, and confirm their identity. The final financial monitoring and income verification are carried out by the very bank that issued the card and has a complete file on the customer. Requiring the terminal to duplicate this work—without access to bank databases due to banking secrecy—is illogical, to say the least.

Legal limits up to 5,000 hryvnias: By law, small transfers up to 5,000 UAH have a simplified verification process—a code sent to a mobile phone is sufficient. Attempts to penalize companies for such fast transactions appear to be a penalty for operating within the law.

“Geographical oddities”: The regulator is outraged that cards in different cities across Ukraine were topped up using the same phone number within a matter of minutes (which is physically impossible to do in that time). But in the digital age, it’s much simpler: a person stands at a terminal in Kyiv, while a relative or business partner in Lviv dictates the code that was sent to their phone. A terminal is not the police; it has no authority to track the geolocation of a mobile financial number—it merely verifies that the numbers are entered correctly.

Cameras and “phantom lines”: The inspectors’ complaints about the speed of transaction processing on video cameras seem somewhat strange, since modern digital systems process data in milliseconds. Furthermore, analyzing video footage to investigate crimes is the job of law enforcement agencies (the Security Service of Ukraine, the National Police), not civilian auditors from the National Bank during a routine document review.

War-related force majeure: It is, at the very least, unfair to blame payment systems for the fact that, in 2024–2026, some SMS confirmations were delayed due to blackouts and mobile network outages. Businesses did everything possible to ensure that, even during power outages, people could still pay their utility or phone bills.

A separate issue concerns the objectivity of the NBU’s decisions regarding the imposition of sanctions. Ukrainian judicial practice shows that the regulator often loses to financial institutions if its inspectors rely on their own assumptions rather than the letter of the law. The regulator has already lost court cases involving similar matters, such as those involving RVS Bank, the International Investment Bank, and WayForPay.

According to our sources at the NBU, lawyers within the agency itself are well aware of the risks: if they act purely on emotion or based on internal instructions that contradict the law, the courts will completely overturn such decisions.

Why bleed individual companies
  dry?

Independent payment terminals facilitate a massive cash flow—experts estimate around $1 billion per month. If these networks (which control over 70% of the market) were to shut down, people would not stop using these services. The money would simply end up in other hands.

Therefore, there are likely three possible explanations:

A monopoly by state-owned banks. If private networks are eliminated, millions of Ukrainians will turn to the teller windows and terminals of state-owned banks. This will allow them to dictate their own terms and raise fees for the public. And this, in turn, could indicate that the NBU is violating the IMF’s decision to reduce the share of state-owned banks in the economy.

A spot for “their own” player. If EasyPay and City24 lose their prime locations in supermarkets and shopping centers, a new payment system—potentially loyal to one of the high-ranking officials—could quickly take their place.

Blatant pressure and “subscription fees.” Behind the scenes in the financial sector, there is active discussion of the theory that the real goal of such massive fines is not to shut down the companies, but simply to intimidate them. Perhaps they are simply trying to force businesses to pay an under-the-table “tribute” to their handlers in the corridors of power in exchange for the right to continue operating undisturbed. It seems that fines of 135 million are a kind of financial bargaining chip in these negotiations.

NBU
Leadership at the Center of Political Scandals
 

The reputational crisis within the National Bank itself likely reached its peak during the exposure of high-level corruption as part of the “Midas” and “Forest Gump” special operations. The materials released following both anti-corruption investigations showed that the NBU increasingly resembles not an independent arbiter but a subjective player in the financial and political backrooms. 

Anti-corruption investigations by NABU and SAPO. Despite attempts to artificially drag the private payment systems EasyPay and City24 into the so-called “Mindichgate,” the actual audio recordings suggest otherwise—the conversations directly mention the name of NBU Governor Andriy Pyshnyy, whom former top officials and shadow lobbyists refer to in the context of coordinating actions. This creates an obvious conflict of interest, as the regulator attempts to shift the media spotlight onto legitimate businesses in order to dispel the toxic aura surrounding its own leadership. The materials from Operation “Forest Gump” have added even more controversy to the logic behind the NBU’s financial monitoring. According to the details of the case, the organizers of the corruption scheme took de facto control of the state-owned Sens Bank and then “laundered” illicit cash through it. The amounts involved were substantial, running into hundreds of millions of hryvnias. The expose raised questions about potential problems within the NBU itself, which failed to detect large-scale abuses at the state-owned bank.

An open public conflict has erupted between the chairman of the Verkhovna Rada’s Finance Committee, Danylo Getmantsev, and Andriy Pyshnyy. The essence of the confrontation once again centers on the “Mindich tapes” and the questionable dealings surrounding the nationalized “SENS Bank.” Danylo Getmantsev, head of the Verkhovna Rada’s Tax Committee, directly stated that Andriy Pyshny allegedly knew about the money-laundering scheme at Sens Bank and failed to take the necessary measures earlier. The lawmaker also alleged the possible involvement of Iryna Mudra in the scheme, whom he described as a close associate of Pyshnyy. He also mentioned Pyshnyy’s ties to Vasyl Veselyi and six top executives at Sens Bank. The lawmaker explicitly pointed out that appointments to the bank’s senior management were lobbied for and approved by the NBU leadership in circumvention of transparent procedures and regulations, which undermines trust in the entire banking system.

The NBU’s public war against “Ukrposhta” and its head, Ihor Smiliansky. The National Bank is systematically attempting to block the development of financial services by the national postal operator by leveling baseless regulatory claims against it. However, detailed rebuttals from “Ukrposhta” appear significantly more well-reasoned than the National Bank’s written demands, which only confirms that: the regulator is waging a selective campaign against all players who do not fit into its own backroom model of the market.

When, under the guise of “European regulations,” the public is shown the selective punishment of some and the complete disregard for violations by others—this is an alarming signal. The transformation of the NBU from a technocratic regulator into an instrument of administrative pressure directly threatens the country’s financial stability and jeopardizes our prospects for European integration, since international partners expect Ukraine to follow transparent rules of the game, not a return to practices of manual control over the economy.

 

Comment by a financial expert
 

“I am increasingly concerned not by the fact of the fines themselves, but by their scale and rationale. In financial monitoring, violations can be fundamentally different. It is one thing when a company knowingly facilitates money laundering or poses a real threat to the financial system. It’s an entirely different matter when it comes to shortcomings in procedures, documentation, or internal controls. You can’t punish these things as if there were no difference between them,” emphasizes an expert on the Ukrainian financial market who wished to remain anonymous.

According to him, if the violations by EasyPay and City24 were so serious that each company deserved a fine of 135 million hryvnias, then another question arises: why are they even allowed to continue operating?

“If an institution’s activities pose a systemic risk or if it effectively facilitates the laundering of criminal proceeds, the regulator must suspend or revoke its license and refer the case to law enforcement agencies. If, however, the violations can be remedied, a fine capable of crippling the business appears clearly disproportionate.

In the case of iPay, the situation is even less clear. Publicly, the NBU cites inadequate control over the quality and sufficiency of information accompanying payment transactions. In other words, it is not about proven money laundering, fraud, or damages caused to anyone, but rather about control deficiencies. At the same time, the company is being fined 16.5 million UAH. According to publicly available data, this amounts to nearly its entire net profit for 2025. This is no longer an incentive to rectify the violations but effectively a confiscation of the company’s annual earnings, notes a financial market expert. — Such practices have direct consequences for the entire market. Businesses begin to fear developing new products and investing; they factor regulatory risks into their commissions, scale back services, or leave the market altogether. As a result, competition decreases, and consumers end up paying the price.

Strict oversight of the financial market is necessary. But its logic must be clear: a dangerous participant is removed from the market, while a company that has committed a correctable violation is given an order to rectify it and is subject to a proportionate penalty. Allowing a company to continue operating while simultaneously depriving it of the resources needed for development and strengthening oversight does not restore the business to health—it bleeds it dry.”

Read also: NBU Governor Pyshnyy’s 
personal decision: Ukraine’s all-time record—fines totaling 135 million UAH for EasyPay and City24

 

Read us on Telegram and Sends