UKRN CB PSP Management Systems


On Jul. 5, UKRN CB proposed rules for payment service providers.


  • UKRN CB proposed reg on requirements for management system of non-bank payment service providers, which stipulates requirements for corporate governance system.
  • Summary
  • The regulation is going to apply to payment institutions (except small ones), electronic money institutions and postal operators providing financial payment services.
  • Also, branches of foreign payment institutions and foreign e-money institutions.
  • The regulation requires for non-bank payment service providers to establish separate divisions for internal audit, risk management, and compliance control or or assign these functions to the internal auditor, chief risk manager, chief compliance manager.
  • The risk manager and compliance manager have veto power over executive body decisions related to: the business model of the financial payment service provider.
  • As well as the internal control and risk management system and the tariff policy.
  • The regulation outlines a list of key internal documents required for management systems, including: provisions on the internal control system and internal audits.
  • And compliance control, code of conduct, provisions on internal control system, risk management strategies, declarations of risk appetite and risk management policies.
  • Effectiveness
  • Comments and feedback are expected by Jul. 26, 2024.
  • Oct. 2024 Law Issued
  • On Oct. 28, 2024, UKRN CB introduced regulation for systems of corporate governance, internal control, risk management of financial payment services providers.
  • Providers of financial payment services will have time to bring their activities into line with the new requirements according to a schedule that includes the following stages.
  • Implementation of organizational measures and documents on internal control system issues - until Nov. 15, 2024; implementation of strategies, policies, methods and procedures - by Dec. 1, 2024; implementation of the declaration of exposure to risks and ensuring compliance with other requirements - until Dec. 31, 2024.
  • Full transition to the fulfillment of the new requirements is expected from Jan. 1, 2025.
  • To bring them into line with the new requirements, changes also made to Regulation on the procedure for authorization of the activities of financial payment service providers and limited payment services and Regulation on the authorization of financial service providers and conditions for their performance of financial service activities.
  • These changes were approved by resolutions No 123 of Oct. 10, 2024 On approval of the Regulation on requirements for the management system of the provider of financial payment services and No. 128 of Oct. 25, 2024 On amendments to some regulatory legal acts of National Bank of Ukraine which take effect from Oct. 29, 2024.

Regulators UKRN CB
Entity Types MSB
Reference PR 10/28/2024; Res 123, 10/10/2024; Res 128, 10/25/2024; PR, 7/5/2024
Functions Audit; Compliance; Financial; Legal; Operations; Reporting; Risk; Technology; Treasury
Countries Ukraine; Cross-Border
Category
State
Products Forex; Payments
Regions EMEA
Rule Type Final
Rule Date 7/5/2024
Effective Date 1/1/2025
Rule Id 218556
Linked to N/A
Reg. Last Update 10/28/2024
Report Section International

Last substantive update on 10/30/2024