A total of 922,500 (nine hundred twenty-two thousand and five hundred) GEL was fined to the Currency Exchange Office LTd „BITCROSS” (Identification Number: 400398066)

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

In the case of 1,647 (one thousand six hundred and forty-seven) operations (transactions), has been revealed the facts of failure to record the relevant information/documentation for the verification of the person acting on behalf of the client, which, in accordance with Article 3, Paragraph 4, Subparagraph "b" of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020, it envisages a fine of 500 (five hundred) GEL for each fact of violation, in total 823,500 (eight hundred twenty-three thousand and five hundred) GEL;

23 (twenty-three) cases of providing services to persons without verification, which, in accordance with Article 3, Paragraph 3, Subparagraph “b” of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020, it envisages a fine of 1,000 (one thousand) GEL for each fact of violation, in total 23,000 (twenty-three thousand) GEL;

1 (one) case of failure to determine the essence of the client's activity and/or the purpose and intended nature of the business relationship, which, in accordance with Article 3, Paragraph 3, Subparagraph "t" of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020, 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 “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020, 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 the interconnected persons 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 “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020,, it envisages a fine of 10,000 (ten thousand) GEL.