MainPublications of our law firmComments on legislationWhich requirements are given to the Head of cash in transit department of a legal entity by obtaining the license on the collection service?

Which requirements are given to the Head of cash in transit department of a legal entity by obtaining the license on the collection service?

On December 24, 2015, the Resolution of the Board of Directors of the National Bank of Ukraine No. 926 was approved that establishes the general procedure and conditions of issue of license for providing for the banks the cash-in-transit services that (the license) is issued to legal entities by the National Bank (hereinafter referred to as the NBU) of Ukraine

However, it should be noted that now there are few private companies that managed to get a license for cash-in-transit-services. First of all, that is connected with a rather complicated procedure of license issuing, and also with not less serious provisions concerning the licensees. And that all in spite of considerable financial support required for keeping the cash-in-transit subdivisions.

Among other requirements, a legal entity, to provide cash-in-transit services for the banks, should comprise the corresponding staff (the employees should have a certain qualification, have training and pass successfully tests in specialty).

In this article, the requirements will be considered that are set directly for the legal entity cash-in-transit services subdivision head.

According to the above Resolution, a legal entity, along with other documents, should provide to the NBU a certified copy of the order about creation of cash-in-transit services subdivision and copies of documents certifying availability of the required training (additional training, instruction) of the staff of that subdivision in the corresponding education institutions.

Besides actually Resolution of the NBU No. 926 dated 24.12.2015, the Procedure of creation and activity of the cash-in-transit service subdivision is regulated by the Resolution of the Board of Directors of the National Bank of Ukraine dated March 31, 2017 No. 29 by which the Instruction on organization of cash-in-transit services of funds and transportation of banks’ currency valuables in Ukraine was approved.

Thus, according to the Resolution of the NBU No. 926 dated 24.12.2015 (sub-clause 19 clause 10), for getting a license for cash-in-transit services, a legal entity should submit to the NBU the biographic information about the head of the cash-in-transit service subdivision head and the documents confirming that the head of the cash-in-transit service subdivision has the following:

  • complete higher legal or economic education and working experience above three years in senior management positions at law-enforcement authorities (military formations and training in the matters of organization of transportation of currency valuables and cash-in-transit of funds, subdivisions of paramilitary security services, which is confirmed with the corresponding certificate), or complete higher education and working experience above two years in senior management positions in the sphere of cash-in-transit services and transportation of cash or banking security;
  • certificate of the Ministry of Internal Affairs of Ukraine (not older than one month upon the day the documents are submitted) confirming that the head of the cash-in-transit service subdivision has no criminal records;

When appointing a person to the position of the head of the cash-in-transit subdivision, it is required that the person who is appointed meets the following criteria:

  1. Complete higher education (without definite specialty) with simultaneous length of work above two years in senior management positions in the sphere of banking security (head of the bank cash-in-transit service subdivision). Length of work is to be confirmed with records in the work book.
  2. Higher economic or legal education, and also length of work above three years in senior management positions at law-enforcement authorities, subdivisions of paramilitary security services, military formations (length of work is to be confirmed with records in the work book, or subdivisions of training in the matters of organization of transportation of currency valuables and cash-in-transit of funds (to be confirmed with a corresponding certificate).
In turn, the following bodies belong to the law-enforcement authorities:
  • prosecution authorities;
  • internal affairs authorities;
  • state tax service authorities (tax militia);
  • military police at the Armed Forces of Ukraine;
  • customs authorities;
  • state control and auditing service authorities;
  • national border control services;
  • pretrial detention centers;
  • law enforcement authorities and facilities;
  • security services;
  • state forest protection bodies;
  • fishery protection bodies;
  • other authorities that perform law enforcement functions or duties.                                

Conclusions

Thus, before getting a license for cash-in-transit services, there should be a person complying with the established license provisions.

Because that is one of the main requirements which a licensee should provide. Without that requirement it will be impossible to get a license for cash-in-transit services, even if all the other requirements are complied with. And since nowadays not every bank in Ukraine has a cash-in-transit subdivision in its (bank’s) structure, so there are not so many persons with the length of service as a head of that subdivision, either.

Do you want to know more about the license for cash-in-transit services? Please call: 0 800 330 967



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