A total of 30,000 (thirty thousand) GEL was fined to the Currency Exchange Office LTd „KORUKHI” (Identification Number: 400427267)

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 № 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” (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 3,000 (three thousand) GEL;

As of the date of commencement of the inspection, has been revealed 1 (one) facts of failure to submit the transaction reports (CTR) to the Financial Monitoring Service of Georgia 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 Financial Monitoring Service of Georgia dated June 5, 2020, which, in accordance with Article 3, Paragraph 3, Subparagraph “l” of the Penalty Rules, it envisages a fine of 2,000 (two thousand) GEL for each violation, in total 2,000 (two thousand) GEL;

The currency exchange office did not investigate the essence of transaction in relation to 4 (four) clients required by the Article 10, Paragraph 5 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”, which, in accordance with Article 3, Paragraph 3, Subparagraph "g" of the Penalty Rules, it envisages a fine of 3,000 (three thousand) GEL for each person, in total of 12,000 (twelve 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 related transactions and the interconnected persons and verification of all individuals and legal entities in the lists of sanctioned and politically exposed persons, besides the software system cannot record information required for Know Your Customer (KYC) questionnaires, which, in accordance with Article 3, Paragraph 2, Subparagraph "e" of the Penalty Rules, it envisages a fine of 10,000 (ten thousand) GEL.