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Oleksii Shaban: How National Bank managed to ensure routine operation during Russia’s full-scale war

May 13, 2022 12:44 AM 3 min read
The National Bank of Ukraine has been successfully keeping the country's bank system afloat after Russia launched a full-scale invasion of Ukraine on Feb. 24. (
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Since 2014, the National Bank of Ukraine (NBU) has factored into its forecasts the risk of escalation of Russia’s military aggression.

Therefore, the regulator has a clear framework for responding to various events that ensure the reliable and constant operation of Ukraine’s banking system, the preservation of public funds, and the continuity of payments.

The NBU’s business continuity plan covers the operational stability of banks, the NBU’s system of electronic payments, the availability of cash to customers, and the guarantee of customer deposits. Special attention is paid to ensure the cyber resilience of the NBU and the banking system as a whole.

The regulator also requires business continuity plans from banks to be drafted in advance.

Alongside efficient business models, these steps have prevented the halting of banking operations during the onset of Russia’s full-scale war.

The Ukrainian banking sector’s high degree of digitalization and the broad usage of remote financial services has also played a role.

These components are advanced due to the development of the “cashless economy” in Ukraine, as well as 2020 amendments to laws and NBU regulations that enable the remote identification and verification of financial institution customers, including the application of the NBU BankID System.

Furthermore, during the first few weeks of the full-scale war, the NBU authorized banking institutions to process and store information on the Cloud. In the event of the destruction of physical banking infrastructure, banks are able to quickly resume routine operations and preserve critical information.

As a result, despite the difficult circumstances at hand, the NBU and the banking system operate smoothly and effectively, assuming responsibility for preserving customer funds, ensuring payments, and supporting the economy.

The NBU ensures the undisrupted, business-as-usual operation of the System of Electronic Payments (SEP). In particular, the regulator provisionally deploys the backup on reserve sites. Therefore, at present, much like during times of peace, the SEP operates 24/7.

All Ukrainian banks are connected to the SEP and make payments to customers on a regular basis. In batch mode, a payment from a sending bank to a recipient bank takes no more than 20 minutes on average and funds are credited instantly.

Banks and payment systems perform bank card settlements and operate payment infrastructure around the clock.

Payment card transactions by international payment systems (e.g., MasterCard and Visa), as well as the PROSTIR national payment system, are also executed 24/7. Payment cards can be used for payments across all of Ukraine, provided there is connection and no ongoing hostilities.

Furthermore, banks support proprietary mobile services and online banking, and customers have constant remote access to managing their funds.

The remote identification and verification system and the NBU BankID System also operate regularly. The stable operation of the NBU BankID System is essential for Ukrainian households, especially during the current status of martial law, as it guarantees free and constant access to state and financial services.

State agencies use the NBU BankID System to identify individuals in Ukraine’s Diia mobile app, which provides users with smartphone access to state services, as well as provides financial aid as part of the ePidtrymka program. Banks use the system to provide remote account opening services for individuals that are unable to access a physical bank due to forced displacement or their local bank’s inability to service customers in person.

Provided there are no threats to the well-being of both customers and banking personnel, banks in Ukraine ensure the continued operation of their offices and replenish ATMs so that customers may easily access their funds.

The NBU delivers cash to banks and ensures the continued liquidity of the banking system.

Moreover, at the beginning of Russia’s full-scale war, the NBU recommended that retail companies provide cash withdrawals to meet public needs. Banks and payment systems were eager to support the initiative. This service was arranged by 25 Ukrainian card-issuing banks to their customers.

At present, over a thousand retail companies across Ukraine are able to disburse cash directly from their cash desks when using a payment card.

According to data collected by the NBU, at least 35,000 ATMs support these transactions. The decision to introduce such transactions has been timely and meets the public demand for Ukrainian hryvnias in cash.

In March, cash payouts from cash desks of retail companies accounted for Hr 3.8 billion.

Having understood that the continuity of cashless payments by businesses decreases the public demand for cash, the NBU has not introduced limitations in this area. A temporary limit of Hr 100,000 per day for cash withdrawals in Ukraine allows for the satisfaction of customers’ priority needs.

So how did the National Bank manage to ensure routine operation during Russia’s full-scale war? Thorough preparation.

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