Anti-money-laundering
Payment Structuring as Money Laundering in Ukraine
Why splitting payments below Ukraine's UAH 400,000 financial monitoring threshold exposes laundering, and what economic expertise can establish.
9 min read →
← All blog topics
Blog category
Anti-money-laundering
Money-laundering typologies in the Ukrainian context, financial monitoring and conversion centres.
Laundering the proceeds of crime — Article 209 of the Criminal Code — has a mandatory precondition: a predicate offence that generated those proceeds. Without a proven criminal source there is no laundering offence, which is why the economic side of such cases comes down to the origin of the funds and documentary proof of a lawful source.
The second layer is financial monitoring under Law No. 361-IX. Banks, payment institutions, notaries, estate agents, accounting and law firms are primary financial monitoring entities: they identify clients, study their activity and report threshold and suspicious transactions. A threshold transaction is one of UAH 400,000 or more (lower for certain categories of entity) that carries one of the features listed in the law.
The typologies an expert meets most often are structuring amounts below the threshold, pass-through companies and conversion centres, cash settlements without economic substance, and loans from related parties with no real movement of money. This section also covers what to do when a bank suspends a transaction and which documents evidence a lawful source of funds.
Articles in this category
Anti-money-laundering
Conversion Centres in Ukraine: How Schemes Are Exposed
What a conversion centre is, how Ukraine's BEB and tax service expose one, and why buying cash conversion endangers the client business itself.
8 min read →
Anti-money-laundering
Ukraine's UAH 400,000 Financial Monitoring Threshold
Threshold financial monitoring in Ukraine: the UAH 400,000 rule, four triggers under Article 20 of Law No. 361-IX and why structuring backfires.
8 min read →
Anti-money-laundering
The Predicate Offence in Ukrainian Laundering Cases
What a predicate offence means under Article 209 of Ukraine's Criminal Code, whether a separate conviction is needed, and what expertise proves.
11 min read →
Anti-money-laundering
VAT Skrutka in Ukraine: Schemes, Liability and Defence
What VAT skrutka is, how the tax pit, transit firm and beneficiary chain works in Ukraine, and how to prove that your transactions were genuine.
9 min read →
Anti-money-laundering
Article 209 of Ukraine's Criminal Code: Money Laundering
When liability arises under Article 209 of Ukraine's Criminal Code: the elements of laundering, sanctions and the role of economic expertise.
9 min read →
Anti-money-laundering
Primary Financial Monitoring Entity in Ukraine: Duties
Who is a primary financial monitoring entity under Ukraine's Law No. 361-IX, the duties (registration, CDD, reporting) and the penalties for breach.
9 min read →
Anti-money-laundering
Economic Expertise in Ukrainian Money-Laundering Cases
What economic expertise establishes in Ukrainian money-laundering cases: the objects, the methods, specialities 11.1-11.3 and the right questions.
9 min read →
Anti-money-laundering
Crypto Money Laundering: Financial Monitoring in Ukraine
Why cryptocurrency is not anonymous to the state: how Ukraine monitors virtual asset transactions and what crypto exchanges are required to report.
9 min read →
Anti-money-laundering
Frozen Account in Ukraine: Time Limits and How to Unblock
A Ukrainian bank froze your payment or account? The time limits under Law No. 361-IX, two, seven and up to thirty days, and how to unblock it.
9 min read →
Frequently asked questions
What is a predicate offence and why is Article 209 impossible without one?
A predicate offence is the act that produced the property: tax evasion, embezzlement, fraud, corruption offences. Article 209 punishes what is done with that property afterwards — transfer, conversion, concealment of its origin. If the criminal origin of the funds is not proven, a charge under Article 209 does not hold.
Which transaction amounts fall under financial monitoring?
Threshold transactions are those of UAH 400,000 or more (a lower threshold applies to certain categories of entity) that carry one of the features listed in Law No. 361-IX. Regardless of amount, a monitoring entity must report any transaction it regards as suspicious.
What should you do if a bank suspends a transaction?
Suspension runs for a period limited by law, so the client's task is to file, quickly, the documents evidencing the economic substance of the transaction and the source of the funds: contracts, primary documents, tax reporting, proof of earlier income. Silence is almost always read against the client.
Can an examination prove money laundering?
The expert establishes the movement of funds and whether the source and economic substance of the transactions are documented. Qualifying the conduct under Article 209 is for the court. Yet without economic analysis a laundering charge usually stays at the level of assumption.