A total of 85,000 (eighty-five thousand) GEL was fined to the Currency Exchange Office „INDIVIDUAL ENTREPRENEUR LIA KAPANADZE” (Identification Number: 21001001748)

The currency exchange office did not submit the initial registration form to the Financial Monitoring Service of Georgia. Failure to submit the initial registration form defined by Article 1, Paragraph 3 of “Rules for Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia” approved by Order № 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020, which, in accordance with Article 3, Paragraph 2, Subparagraph “a” of the “Rules for Determining, Imposing and Enforcing the Fines to Currency Exchange Offices and their Administrators” (hereinafter “Penalty Rules”) approved by Order № 17/04 of the President of the National Bank of Georgia dated February 5, 2020, envisages a fine of 3,000 (three thousand) GEL;

9 (nine) facts of failure committed by a currency exchange office to record information regarding its clients and operations (transactions) through a special software (electronic) system, which, in accordance with Article 3, Paragraph 2, Subparagraph "k" of the Penalty Rules, it envisages a fine of 7,000 (seven thousand) GEL for each fact of violation, in total 63,000 (sixty-three thousand) GEL;

6 (six) cases of providing services to persons without identification/verification, which, in accordance with Article 3, Paragraph 3, Subparagraph “b” of the Penalty Rules, it envisages a fine of 1,000 (one thousand) GEL for each fact of violation, in total 6,000 (six thousand) GEL;

Failure to comply with the requirements set forth in Article 29, Paragraphs 1 and 2 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”. In particular, the currency exchange office fails to ensure the fulfillment of obligations related to the implementation of internal control and monitoring for the purposes of preventing money laundering and financing of terrorism. The document is characterized by significant gaps, it cannot meet the requirements defined by the legislation (as well as the guidelines of the National Bank of Georgia), which, in accordance with Article 3, Paragraph 3, Subparagraph “i” of the Penalty Rules, it envisages a fine of 3,000 (three thousand) GEL;

Failure to comply with the requirements set forth in Article 27, Paragraph 6 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”. The software (electronic) system implemented in the currency exchange office for the purposes of preventing money laundering and financing of terrorism, functions with significant shortcomings. In particular, it fails to ensure the detection of suspicious/unusual transactions and the verification of individuals and legal entities in the lists of sanctioned and politically exposed persons, which, in accordance with Article 3, Paragraph 2, Subparagraph "e" of the Penalty Rules, it envisages a fine of 10,000 (ten thousand) GEL.