Today, within the walls of the Ukrainian parliament, the fate of every citizen’s financial privacy is being decided. On the lawmakers’ agenda is Government Bill No. 13233, which—under the banner of European integration—proposes revolutionary changes that some find alarming.

The official goal sounds noble: to bring Ukrainian legislation in line with EU standards for joining the Single Euro Payments Area (SEPA). This undoubtedly promises us cheaper and faster money transfers with Europe. However, as is often the case, the devil is in the details, and behind the attractive facade lie mechanisms capable of radically altering the relationship between the state and its citizens. Let’s take a closer look at what this document actually proposes, what benefits it offers, and what risks it conceals.

“Big Brother” at Your Bank: The Account Registry

The key and most debated provision of the bill is the creation of a registry of accounts and individual bank safes held by private individuals. At first glance, this sounds like a technical detail, but in reality, it involves creating a single centralized database that will collect information on all—without exception—bank accounts, e-wallets, and even bank safety deposit boxes opened in the names of individuals in Ukraine.

How will this work in practice? Imagine that you’ve decided to open a new bank account to save for a vacation or simply as a payroll account. The moment you sign the agreement, the bank will be required to electronically notify the tax service, which, according to the draft bill, will become the custodian of this comprehensive registry. It is important to note that, according to the drafters of the bill, information about account transactions or the account balance will not be transmitted to the registry. The registry will only contain the fact that the account exists, its number, the dates it was opened and closed, and the account holder’s details.

However, this raises a logical question: who will have access to this database, and for what purpose? The list of users is, to put it mildly, impressive: it includes not only tax authorities but also the State Financial Monitoring Service, the National Anti-Corruption Bureau (NABU), the Economic Security Bureau, the National Agency for Corruption Prevention (NAZK), as well as public and private enforcement agencies. Thus, any of these agencies will be able to quickly obtain a complete list of your financial “wallets.” This significantly simplifies, for example, the process of collecting debts or child support, since the enforcement agent will not have to send requests to every bank in the country at random.

Beneficiary Transparency and the Whistleblower System: New Rules of the Game

The next set of changes concerns two key elements of any modern anti-money laundering system: maximum transparency of ownership and protection for those who help ensure that transparency.

First, the draft law takes a decisive step toward eliminating “blind spots” in the ownership structure of assets. Although information on the ultimate beneficial owners (UBOs) of Ukrainian companies is already contained in the Unified State Register, the main problem has always been the lack of transparency in foreign structures.

The bill targets precisely these structures—specifically, trusts and other similar legal entities. This is a classic instrument of Anglo-Saxon law that has no direct equivalent in the Ukrainian legal system and is often used to conceal the true owners. For example, a Ukrainian factory may be owned by a company based in Cyprus, which, in turn, is managed by a trustee of a trust established somewhere in the British Virgin Islands. Until now, it has been nearly impossible to identify the actual beneficial owner. Now, however, by implementing the requirements of the EU’s Fifth Anti-Money Laundering Directive (5AMLD), the draft law establishes a separate Register of Beneficial Owners of Trusts. The obligation to disclose the entire ownership structure—from the settlor to the ultimate beneficiary—rests with the trustee if the trustee is a resident of Ukraine or enters into a business relationship here. This forces those who previously hid behind the shield of foreign jurisdictions to come to light.

Second, recognizing that no registry will be effective without insider information, the legislature is significantly strengthening the institution of whistleblowers in the financial sector. Following the EU Whistleblower Protection Directive, the draft law grants immunity from any retaliatory (punitive) measures to those who report suspicious financial transactions. This means that a bank clerk or financial analyst who reports a money-laundering scheme cannot be fired, demoted, denied a bonus, or subjected to any other form of pressure. However, according to experts, there are also weaknesses here. Unlike whistleblowers who expose corruption, their “financial” counterparts do not yet have a clear procedural status in criminal proceedings and, importantly, are not entitled to monetary compensation. This could significantly reduce the motivation to report complex and convoluted financial schemes, the exposure of which requires considerable effort and entails personal risks.

Two Sides of the Coin: Benefits and Risks

Undoubtedly, the proposed changes hold significant positive potential. First, joining SEPA offers real, practical benefits for millions of Ukrainians and businesses. Transferring funds in euros to EU countries will become just as easy and inexpensive as transfers within Ukraine. Second, increasing the transparency of the financial system deals a powerful blow to corruption, tax evasion, and money laundering. In theory, this should increase budget revenues, which fund the military, healthcare, and education. Ultimately, this fulfills our international obligations and represents another step toward full membership in the European Union.

On the other hand, we cannot ignore the serious risks that raise a key question: Is our country ready for such tectonic changes? The greatest concern is the issue of privacy and data protection. Creating a massive database of all citizens’ financial accounts is a huge responsibility and, at the same time, an extremely attractive goal. In the context of a permanent state of war, when hostile cyberattacks on state resources have become commonplace, will we be able to guarantee 100% security for this registry? A leak of such information could lead not only to financial losses but also to the use of this data against Ukrainian citizens by enemy intelligence services.

The problem of internal threats is no less acute. We’re talking about the human factor and unscrupulous officials. Even the most sophisticated security system is powerless against a corrupt administrator who, for a bribe, is willing to leak information from the registry. This opens the door to blackmail, corporate raiding, and the use of data in political struggles. Might this tool, designed to combat corruption, end up becoming a new source of corruption itself?

Furthermore, there is a risk of abuse of the system itself. Could it become a means of exerting pressure on disloyal businesses or civic activists?

To minimize this threat, the state must implement a multi-tiered system of safeguards. First, there must be a clear legislative framework: the law must unambiguously define an exhaustive list of grounds for requesting information by each specific agency. For example, for a private enforcement agent—only the existence of open enforcement proceedings, and for NABU—only within the scope of a registered criminal proceeding. Second, robust technical safeguards are necessary, including not only encryption but also the creation of an immutable audit trail. Every query to the registry and every data access must be recorded in a separate log file, specifying the individual, the time, and the grounds for the request. Third, independent external oversight is critically important. This could take the form of a special parliamentary committee or a separate data protection commissioner (ombudsman) with the authority to conduct unannounced audits of access logs and investigate complaints from citizens. Without such a system of oversight, the risk of a useful tool becoming a repressive one remains extremely high.

Conclusion: The Price of a European Ticket

To summarize: Bill No. 13233 is a classic example of a double-edged sword. On the one hand, it offers us a ticket to the European financial space and strengthens the fight against the shadow economy and corruption. On the other hand, the price of this ticket may turn out to be high, and we will have to pay for it with a portion of our financial privacy.

The intention to make the financial system more transparent is, of course, the right one. However, the success of this reform will depend not so much on the adoption of the law as on its subsequent implementation. Will the state be able to ensure reliable protection of the registries it creates? Will clear and effective safeguards be put in place to prevent abuse by regulatory authorities? The answers to these questions will determine whether this law will become a tool for building a modern European state or turn into a mechanism of total control. For now, Ukrainian society should closely monitor the fate of this initiative, as it affects everyone.