A total of 20 400 (twenty thousand four hundred) GEL was fined to the Currency Exchange Office LTd „AKO” (Identification Number: 412715799)

As of the date of commencement of the inspection, has been revealed 16 (sixteen) facts of delayed submission (up to 5 working days) of the transaction reports (CTR) defined by Article 6, Paragraph 4 of the “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, to the Financial Monitoring Service of Georgia, which, in accordance with Article 3, Paragraph 4, Subparagraph “a.a” of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against 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, it envisages a fine of 100 (one hundred) GEL for each violation, in total 1,600 (one thousand six hundred) GEL;

As of the date of commencement of the inspection, has been revealed 6 (six) facts of delayed submission (5 and more working days) of the transaction reports (CTR) defined by Article 6, Paragraph 4 of the “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, to the Financial Monitoring Service of Georgia, which, in accordance with Article 3, Paragraph 4, Subparagraph “a.b” of the Penaly Rules, it envisages a fine of 300 (three hundred) GEL for each violation, in total 1,800 (one thousand eight hundred) GEL

As of the date of commencement of the inspection of the currency exchange office, has been revealed the failure of risk assignment/reassessment in relation to 1 (one) client that was carried out without taking into account the relevant risk factors specified in the legislation of Georgia, including the legal act of the National Bank of Georgia on risk assessment and/or the internal policy/procedures of the currency exchange office, which, in accordance with Article 3, Paragraph 3, Subparagraph "v" of the Penalty Rules, it envisages a fine of 2,000 (two thousand) GEL in relation to each client, in total 2,000 (two thousand) GEL;

1 (one) case of failure to determine the essence of the client's activity, which, in accordance with Article 3, Paragraph 3, Subparagraph "t" of the Penalty Rules, it envisages a fine of 2,000 (two thousand) GEL in relation to each client, in total 2,000 (two 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/fragmented transactions and verification of all 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.