Despite the fact that the period of mass information campaigns on the mandatory updating of military registration data by citizens has long ended. The CCC and the SP have only now moved from mass mailing of summonses to gradual prosecution. The main trigger in social networks now: the mass imposition of fines by the Territorial Recruitment Centers (CCC and SP) under Articles 210 and 210-1 of the Code of Administrative Offenses , which is reflected in the personal accounts of military personnel in the Reserve+ application. However, the problem is much deeper, because the timely failure to pay such a fine leads to the instant blocking of bank accounts through the State Enforcement Service.
Few people know that a fine of UAH 17,000 is just the starting point. If you ignore the process, the amount of the collection not only automatically doubles to UAH 34,000, but also adds a mandatory commission of the State Enforcement Service for their services for forced collection in the amount of 10% of the doubled amount. That is, in total, the violator will have to pay UAH 37,400 instead of the usual UAH 17,000 to close the enforcement proceedings and unblock access to their own bank accounts. Below in this material we will analyze in detail how this mechanism works, who is at the highest risk of losing access to accounts with a double fine, and how to protect your funds and rights.
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What is the fine for: Articles 210 and 210-1 of the Code of Administrative Offenses
First, you need to understand and clarify why the CCC is currently mass-prosecution and what types of administrative offenses you have committed over the past year are grounds for imposing a fine by the CCC, with the prospect of transferring the case to the enforcement service in case of ignoring it to deprive you of access to your accounts.
| Article | The essence of the violation | Fine (martial law) |
| Article 210 of the Code of Administrative Offenses | Violation of military registration rules: failure to register, failure to notify the CCC of a change in place of residence, marital status, education, or work. | From 17,000 to 25,500 UAH |
| Article 210-1 of the Code of Administrative Offenses | Violation of mobilization legislation: failure to appear for a summons, refusal to undergo a military medical examination (VLK), failure to update data within the established deadlines. | From 17,000 to 25,500 UAH |
Important to remember: According to the new amendments to Resolution No. 560 , the CCC and the SP have the right to issue a fine in absentia . If the summons was sent by registered mail to the registration address, and the post office returned it with a note “addressee absent” or “refusal to receive”, this is considered a proper notification of the conscript about military duty during martial law.
Whose bank accounts are being blocked en masse now?
Many people believe that a fine issued to you for violating military registration rules can simply remain “hanging” in the Reserve+ application system. However, this very mistake in practice leads to the fact that one day you receive a notification from the bank “bank accounts blocked due to enforcement proceedings from the CCC and SP.”
So, to understand whose bank accounts are currently being massively blocked and whether you are in the risk group, it is worth understanding the procedure for bringing to justice in order to understand at what stage your case is and how quickly you need to act.
- Violation of military registration rules . If during the last year you have violated the rules of the military service, such as: failing to appear for a summons, refusing to undergo military service, failing to notify the Central Military Commission of a change of residence.
- Issuance of a resolution. The head of the CCC issued a resolution to impose an administrative penalty on you, based on your voluntary electronic statement of consent in Reserve+, or upon the fact that the CCC and the SP notified you by mail about the date and time of consideration of your case, where you did not appear in a timely manner and did not submit a notification of valid reasons for non-appearance.
- 15 days to pay the fine. From the moment the decision is served (or issued in absentia), the citizen has exactly 15 days to pay the fine voluntarily or appeal it in court.
If you ignore this fifteen-day period, you are at risk of having your bank accounts blocked. After the 15-day period, your case is automatically transferred to the Enforcement Service (EDS) for enforcement. At this point, the fine is doubled (Article 308 of the Code of Administrative Offenses and Administrative Offenses) , UAH 17,000 becoming UAH 34,000. plus an enforcement fee (+10%) and the costs of enforcement actions. The total amount to be collected is about UAH 37,500 .
Having received your resolution from the CCC and the Joint Venture, the executor enters the data into the Automated Enforcement System (ASE), which is integrated with all key Ukrainian banks (Monobank, PrivatBank, FUIB, Sense Bank, etc.), after which all the debtor’s bank accounts are instantly blocked.
If the account is already blocked: what to do?
If your accounts are already blocked by a decision from the CCC and the SP, simply writing letters to the enforcement service will not help. In such a case, you have only 2 legal ways to solve the problem.
Path 1: Legal (Appealing the decision from the CCC and the Joint Venture)
If the fine was issued illegally (for example, you updated your data on time, did not violate the rules of military registration during the last year, have a deferral), the CCC resolution can be canceled through the court. It is necessary to file a lawsuit with the court together with an application for renewal of the deadline for appeal, because this has already expired from the moment the resolution was transferred to the enforcement service. But it is necessary to separately file an application for securing the lawsuit in the form of a ban on collecting funds from your accounts during the trial. The fact of filing a lawsuit with the court itself does not stop the enforcement proceedings without a submitted application “for security”.
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Path 2: Gaining access to some of the funds for living expenses
Under martial law, the law allows debtors to use part of their funds and social accounts that are not subject to blocking. That is, even with arrested accounts, so as not to leave a person without a means of livelihood. You have the right to unblock one of the accounts for an amount equal to two minimum wages per month (currently it is 16,000 UAH).
- To do this, you need to submit a written application (in paper or electronic form with a CEP) to your state bailiff, indicating the account number (IBAN), in which you request the removal of the seizure within the amount guaranteed by law for your own living needs.
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