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Since July 4, 2023, Order No. 662 on supervision in the field of financial monitoring has been in force.

However, inspections under Order No. 662 were never fully initiated due to the moratorium introduced by Resolution of the Cabinet of Ministers No. 303 as of March 13, 2022.

On July 21, 2025, Presidential Decree No. 538/2025 approved the decision of the National Security and Defense Council of Ukraine, which the media has already called a new “moratorium” on inspections.

In this article, we explore:

• whether financial monitoring inspections can actually proceed under current conditions;


• potential risks for businesses;


• key things to know to safeguard your business from abuse by supervisory authorities once inspections resume.

Key points:

• 
  

  The moratorium under Resolution No. 303 applies to financial monitoring inspections conducted by the Ministry of Justice, the Ministry of Finance, and the Ministry of Digital Transformation in accordance with the new Procedure No. 662.

  
  


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  The National Bank of Ukraine conducts inspections regardless of the moratorium, as it is independent of the Cabinet of Ministers and does not follow its resolutions.

  
  


• The National Securities and Stock Market Commission has its own moratorium and carries out inspections only occasionally.


• 
  

  Procedure No. 662 outlines inspection rules, including grounds for unscheduled audits, which must comply with legal requirements.

  
  

The full version of the article is available in Ukrainian by the link.

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