Does a bank have the right to suddenly terminate an agreement?

04.12.2025 18:25 • Question

I learned that the Supreme Court confirmed that a bank can close an account and terminate its relationship with a client if it determines that there is an unacceptably high risk. And I don't quite understand what this means for me as an ordinary client. Can my bank account be closed without warning? What are my rights and should the bank explain the reason for such a decision?

1 Answers

Lorina Fedan

Answer provided 04.12.2025 18:38

In Ukraine, banks can legally and unilaterally terminate a banking service agreement and close a client's accounts. These actions are governed by current legislation, as well as the bank's internal rules.

  1. Violation of the requirements of the Law on Financial Monitoring. The bank may terminate the relationship if the client: refused to undergo identification or verification; failed to provide documents to establish the economic substance of transactions; provided knowingly false or forged documents; could not confirm the source of funds; conducts operations that show signs of being fictitious or are related to money laundering.
  2. Suspicious financial transactions. The volume, nature, or frequency of transactions do not correspond to the business profile; there are signs of schematic capital withdrawal or conversion of non-cash funds into cash; transactions with individuals from "high-risk" jurisdictions are detected; attempts to finance terrorism or other illegal activities are noticed (and the concept of "other illegal activities" can be interpreted at the bank's discretion). To prevent this, the client must be prepared to justify the expediency of transactions using funds in the bank account.
  3. The client or their counterparties being subject to sanctions. If the bank's client: is included in the sanctions lists of Ukraine, the European Union, or the USA; is associated with aggressor states (including Russia and Belarus); is recognized as a member of terrorist or extremist organizations.
  4. The bank's decision regarding its own commercial policy. According to Article 1060 of the Civil Code of Ukraine, a bank account agreement is public, but the bank can refuse it if: this is stipulated in the agreement (and any comprehensive banking service agreement initially provides for the possibility of its unilateral termination by the bank); the client's activities violate the bank's policy or reputational principles; the client abuses their rights; the service has become economically unfeasible for the bank.
  5. Violation of the terms of the agreement. If the client: systematically violates the terms of service; uses the account for purposes other than intended; does not respond to official requests from the bank — the bank has the right to terminate the agreement unilaterally.

The answer is informational and does not replace a full legal consultation. For a detailed analysis of your situation, contact a lawyer directly.