On the imposition of Monetary Fine to the Microfinance Organization JSC "Microfinance Organization Lazika Capital" (Identification Number: 220411132)

    1. During the inspection period, there were 2 (Two) cases of incorrect or late submission of requested information/documentation by the microfinance organization to the Inspection group of the National Bank of Georgia. Which according to the article 3, paragraph 3, subparagraph “p” of the “Rule for determining, imposing and enforcing of the fine to the microfinance organizations and their administrators” (hereafter referred to as "the rule") adopted on February 5, 2020 by the order №16/04 of the President of the National Bank of Georgia considers fining the microfinance organization with the amount of 2,000 (two thousand) GEL on each case. In total, for 2 (two) case of violation mentioned in this paragraph - 4,000 (four thousand) GEL.


    2. During the inspection period, it was revealed that in 4 (four) cases the microfinance organization did not take into account the relevant risk factors while assigning/reassessing client risks, defined by the legislation of Georgia, including the National Bank's legal acts on risk assessment and/or the organization's internal policies and procedures. Which according to the article 3, paragraph 3, subparagraph “v” of the mentioned rule, considers the fine with 3,000 (three thousand) GEL for each violation fact. In sum, 12,000 (twelve thousand) GEL for the 4 (four) violation cases mentioned in this paragraph.


    3. The microfinance organization failed to implement the preventive measures required by Subparagraph 'e' of Paragraph 1, Article 18 of the Law of Georgia on 'Prevention of Money Laundering and Terrorist Financing' for a client assigned a high-risk category. Specifically, the organization did not take reasonable steps to determine the origin of the client's assets and funds. In accordance with Subparagraph 'z' of Paragraph 3, Article 3 of the Rules, this violation results in a fine of 3,000 (three thousand) GEL for each client. For this single violation, the total fine is 3,000 (three thousand) GEL.


    4. The microfinance organization has not determined the nature of the activity for a one client, Which according to the article 3, paragraph 3, subparagraph “t” of the mentioned rule, considers the fine with 2,000 (two thousand) GEL for each client. In sum, 2,000 (two thousand) GEL for the 1 (one) violation case mentioned in this paragraph.