The National Bank of Kyrgyzstan has introduced new indicators of heightened risk relating to the withdrawal of cash by businesses

The National Bank of Kyrgyzstan has established new indicators of heightened risk relating to the withdrawal of cash and transit transactions on the accounts of legal entities and sole traders.

The relevant amendments were approved by Resolution No. 2026-P-12/48-2-(NPA) of the NBKR Board dated 1 October 2026. The document will come into force 30 days after its official publication.

Under the risk-based approach, banks will be required to take into account nine indicators of heightened risk. In particular, these include:

• a significant proportion of the account’s turnover is withdrawn as cash, whilst the volume and frequency of transactions do not correspond to the client’s business activities;
• funds are withdrawn shortly after being credited to the account without any apparent economic rationale;
• funds from one or more counterparties are received and subsequently withdrawn;
• small or interrelated cash-out transactions are carried out regularly without any obvious economic rationale;
• funds received are quickly transferred to third parties, including abroad;
• a recently registered company or sole trader carries out a significant volume of transactions that are inconsistent with the duration and scale of its operations;
• the volume of funds received from abroad for subsequent cash withdrawal is inconsistent with the declared business activities;
• large sums of cash are deposited into an account and subsequently transferred rapidly to third parties;
• corporate bank cards are systematically used primarily for cash withdrawals that are inconsistent with the business’s activities and objectives.

Banks will set specific quantitative thresholds for such transactions independently in their internal documents, taking into account the nature and scale of the customer’s activities, their risk profile and the results of risk assessments.

Where signs of increased risk are identified, the bank must carry out an additional check. In particular, it will analyse the customer’s relationship with the sender or recipient of the funds, the purpose of the payment, the source of the funds, the economic rationale for the transaction and the prior movement of funds.

If the customer fails to provide the necessary documents within the specified time limit, the bank must refuse to process the account transaction.

If, following the verification, the bank has suspicions regarding transactions involving the financing of criminal activity or the laundering of criminal proceeds, it must suspend the suspicious transaction and/or suspend or terminate the business relationship with the customer.

Furthermore, banks must keep separate records of identified high-risk cash-out and transit transactions, including those that were not carried out or were deemed suspicious and in respect of which reports have been submitted to the financial intelligence unit.