The high probability of risk transfer from banks to their counterparties in the field of non-state pension provision (pension account owners, non-state pension funds, insurance companies, asset management companies, etc.) determines the relevance of this study. The paper aims to develop a toolkit for identifying the compliance risk volatility for pension custodian banks based on causal modeling.This toolkit contributes to: 1) tentative cognitive mapping of the causal relationship between the compliance risks of pension custodian banks in the field of financial monitoring and financial and reputational risks to assess their acceptability by stakeholders in non-state pension programs, and 2) impulse modeling. The created toolkit is based on the performance data provided by Ukrainian banks, as well as on the reports of the National Bank of Ukraine. Apparently, an increase in penalty rates by 0.1% would reduce the compliance risks for banks by 0.03%, and the number of violations in financial monitoring (specifically the improper assessment/reassessment of customer risks) by 0.01%. In turn, the compliance risk volatility inherent in custodian banks affects the variability of their reputational and financial risks. Thus, reducing the compliance risks by 0.1% would improve the reputation of banks and increase their regulatory capital by 0.01%.The study findings substantiate the use of the created toolkit to supplement the risk profile components for pension custodian banks, thereby demonstrating the potential volatility of their compliance risks and their consequences for banks and individual groups of their stakeholders. AcknowledgmentThe work is prepared and financed within the framework of the state budget research work No. 45/20202021 “Formation of a risk-oriented system of accumulative pension provision” (DR No. 0120U101508).