1. According to Article 1, Paragraph 3 of Order No.1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020 “On Approval of the Rule on Record-keeping, Storage and Reporting of the Information on the Transaction by Obliged Entity to the Financial Monitoring Service of Georgia”, a brokerage company is required to submit a registration form to the Financial Monitoring Service of Georgia no later than 10 business days after obtaining a license, registration or permit from the supervisory authority. The brokerage company obtained a license from the National Bank of Georgia on November 9, 2021, pursuant to Decree No. 342 of the Vice President of the National Bank of Georgia, despite the above obligation obliged entity submitted the initial registration form to the Financial Monitoring Service late, on October 10, 2023. Which, in accordance with Article 51, paragraph 2, subparagraph “A” of the "Rule for Determining, Imposing and Enforcing Monetary Fines for Violations by Persons and Members of Their Management Bodies of the Securities Legislation, the Law of Georgia on Accounting, Reporting and Auditing, the Law of Georgia on Voluntary Private Pension, and the Legislation on Facilitating the Prevention of Money Laundering and Terrorist Financing" (hereinafter referred to as the “Fine Rule”) adopted on February 14, 2012 by the order No. 35/04 of the President of the National Bank of Georgia, considers fining the brokerage company with the amount of 5,000 (five thousand) GEL;
2. During the inspection period 1 (one) fact of submitted incorrect information/documentation by the brokerage company to the National Bank of Georgia. Which, in accordance with Article 5¹, Paragraph 3, sub-paragraph “O” of the mentioned fine rule, considers the fine with 2,000 (two thousand) GEL for each case. In total, for 1 (one) fact of violation mentioned in this paragraph – 2,000 (two thousand) GEL.
3. The brokerage company assigned the risk for 2 (two) clients without considering the relevant risk factors determined by Georgian legislation, including the legal act of the National Bank on risk assessment. In accordance with Article 51, Paragraph 3, sub-paragraph “F” of the Fine Rules, considers the fine of 3,000 (three thousand) GEL for each case. In total, for 2 (two) fact of violation mentioned in this paragraph – 6,000 (Six thousand) GEL;
4. The policies and procedures developed by the brokerage company fail to meet the requirements set forth in the legislation (as well as the National Bank's guidelines), which, in accordance with Article 51, Paragraph 3, Subparagraph "I" of the Fine Rule, provides for a fine of 5,000 (five thousand) GEL;
5. 1 (one) fact of providing services to a client without verification, which, in accordance with Article 51, Paragraph 3, Subparagraph “B” of the Fine Rules, provides for a fine of 1,000 (one thousand) GEL;
6. The brokerage company does not have a software (electronic) system for the purposes of preventing Money Laundering and Terrorism Financing (which provides of the capability to detect unusual and suspicious transactions, detection of segregated operations (transactions) and automatic verification of the person against the lists of politically active persons subject to sanctions under the sanctions regimes required by the UN security Council of the National Bank in written instructions), Which, in accordance with Article 51, paragraph 2, subparagraph “e” of the Fine Rules, provides for a fine of 20,000 (twenty thousand) GEL.

Brokerage Company LLC “ALPHA CAPITAL ADVISORY” (IDENTIFICATION NUMBER: 405482721) was fined with total amount of - 39,000 (Thirty-nine Thousand) GEL.