Monetary Fine imposED upon Currency Exchange OfficE Ltd “TETIS TRUST” (Identification number: 416295299)

A total of 15,000 (fifteen thousand) GEL was fined to the Currency Exchange Office LTD “TETIS TRUST” (IDENTIFICATION NUMBER: 416295299)

1 (one) case of failure to determine the essence of the client's activities, required by Article 10, Paragraph 4 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 "t" of the “Rule 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 (hereinafter “Penalty Rule”), 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 internal instruction/policy document of the currency exchange office fails to meet the rules established by the legislation of Georgia and the guidelines of the National Bank of Georgia, and is also based on the normative act originally issued by the Financial Monitoring Service of Georgia. Accordingly, the internal instruction/policy procedure submitted by the currency exchange office is characterized by significant faults, which, in accordance with Article 3, Paragraph 3, Subparagraph “i” of the Penalty Rule, 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 unusual related transactions and the interconnected persons and transactions, also 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 Rule, it envisages a fine of 10,000 (ten thousand) GEL.