“Transfer” and “replenishment” are prohibited: How to correctly write the payment details to avoid losing access to your account
Which phrases should be avoided in the payment designation to prevent your account from being blocked.
In Ukraine, financial institutions are increasingly suspending access to bank accounts because of the employment of specific trigger words in payment descriptions, or so-called “questionable” expressions. Legal professionals specializing in monetary oversight are issuing this caution, which bank officials are affirming.
The payment designation is a dedicated section shown during P2P or IBAN transactions, typically positioned underneath the amount being sent. In numerous instances, it's plainly labeled “payment designation,” such as with PrivatBank. Nonetheless, it might occasionally bear an alternative name. For example, Monobank refers to this section as “Comment,” and the user determines the content based on the rationale for the transaction.
Over the past few months, banks have increased their scrutiny of the content within this section and are halting customer accounts if the declared reason for payment is deemed improper.
Trigger words presently categorized as restricted encompass:
• for crypto/cryptocurrency;
• exchange of currency;
• a present if the funds are directed to someone unknown (not a family member);
• transfer or replenishment;
• wage;
• commission;
• down payment;
• debt settlement, when this is not an isolated transaction, but frequent payments (suspicions arise concerning the receipt of unlawful funds);
• for creation, for images, etc., when the funds are being sent to a person, rather than a registered entrepreneur;
• for commodities or services, when the transaction is not directed to the account of a registered entrepreneur.
“We've encountered instances where offensive terminology was applied, like 'deal with it…' and such wordings are already incorporated into our frameworks. We promptly restrict these kinds of transactions and may put a hold on the sender's account. Expressions like 'for goods/services' are forbidden and could lead to the freezing of an account resulting from uncertainties of unlawful commercial operations through a personal account (not a sole proprietorship). The same holds true for the terms 'wage' and 'commission', unless the card serves as a salary card officially provided by the employer. The expressions 'transfer' or 'replenishment' are regarded as dubious because of their lack of specificity. You should delineate, for instance, 'transfer of individual finances.' It's crucial to express the reason for the transaction plainly and explicitly, instead of resorting to generalities,” one financial institution clarified.
Furthermore, it is discouraged to involve individual data in the transaction particulars that is not pertinent to the transaction.
“We've come across diverse circumstances. One client listed their mobile number as the transaction reason, while another provided their email address. In both instances, the accounts were suspended, as it later turned out, automatically due to the bank's system settings. We were obligated to furnish clarifications and fiscal certifications about the provenance of the finances; only then were the accounts reinstated,” a legal advisor at a legal practice disclosed.
To avert account suspension, it is advisable to apply unambiguous phrasing:
• deposit to personal account;
• monetary support when sending funds to relatives;
• for personal use of spouse;
• for securing acquisitions;
• for medical care.
“We similarly propose retaining records of significant acquisitions. Supposing your typical payments are 50-100 UAH, then a substantial sum would be, for instance, 5,000 UAH. And if you generally transact amounts within the range of 3,000-20,000 UAH, then a considerable sum would be considered 40,000 UAH or greater,” monobank elucidated.
Erroneously completed transaction specifics aren't the singular cause accounts have undergone suspension recently; specialists identify supplementary elements as well.
“This could stem from legal proceedings, atypical activity for an individual, or grievances from those purchasing digital currencies,” remarked Rostislav Kravets, senior associate at the Kravets & Partners law firm.
Atypical activity commonly involves frequent transactions appearing almost daily (or multiple times daily), even if the sums are modest, such as 500-1000 UAH. Substantial transactions of 40-50 thousand UAH or greater, when the account has formerly processed minor sums of 4-5 thousand UAH, similarly evoke suspicion.
