A total of 49 050 (forty-nine thousand fifty) GEL was fined to the Currency Exchange Office LTd „DAVITI” (Identification Number: 406206966)

In accordance with Article 5, Paragraph 2, Subparagraph “a” of the “Rules for Registration and Regulation of Currency Exchange Offices” approved by Order № 27/04 of the President of the National Bank of Georgia dated February 7, 2012, and also, in accordance with Article 4 of the Order № 1 of the Head of the Financial Monitoring Service of Georgia dated January 18, 2012 “On Approval of the Regulation on the Procedure for Receiving, Systematizing, Processing and Transmitting Information by Currency Exchange Offices to the Financial Monitoring Service of Georgia”, an Obliged Entity which begins activities after the entry into force of this Order must submit a completed registration form to the Financial Monitoring Service of Georgia no later than 10 days after registration with the National Bank of Georgia. The currency exchange office was registered at the National Bank of Georgia on May 15, 2017. Despite the aforementioned obligation, the currency exchange office submitted the initial registration form to the Financial Monitoring Service of Georgia late, on May 31, 2025, which, in accordance with Article 5, Paragraph 5, Subparagraph “a” of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines for Microfinance Organizations and Currency Exchange Offices” approved by Order № 25/04 of the President of the National Bank of Georgia dated February 7, 2012 (the version in force until June 13, 2017), it envisages a fine of 50 (fifty) GEL;

As of the date of commencement of the inspection, has been revealed 15 (fifteen) facts of failure to submit 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 3, Subparagraph “l” 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 2,000 (two thousand) GEL for each violation, in total 30,000 (thirty thousand) GEL;

3 (three) cases 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 6,000 (six thousand) GEL;

Failure to comply with the requirements set forth in Article 29, Paragraphs one 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 the 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.