under the Article 6, Paragraph 4, of the Rule Financial Monitoring Service of Georgia dated June 5, 2020, during the inspection, there was revealed 1 (one) case of failure to report transaction (CTR) to the Financial Monitoring Service, which, which under the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Points and Their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020. Article 3, paragraph 3, subparagraph “L” envisages a fine of 2,000 (two thousand) GEL, for each case. Total – 2,000 (two thousand) GEL.

under the Article 6, Paragraph 4, of the Rule Financial Monitoring Service of Georgia dated June 5, 2020, during the inspection, there was revealed 8 (eight) case of Incorrect submission transaction (CTR) to the Financial Monitoring Service, which, which under the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Points and Their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020. Article 3, paragraph 3, subparagraph “L” envisages a fine of 2,000 (two thousand) GEL, for each case. Total – 16,000 (sixteen thousand) GEL.

During the inspection, in 19 (nineteen) case, the Currency Exchange Operator had not recorded information about the client and the operation (transaction) through a special software (electronic) system, which under the Article 3, Paragraph 2, sub-paragraph “k” of the Rule Approved by the Decree №17/04 (a version after amendment made on April 6, 2021) of the President of the National Bank of Georgia on February 5, 2020 “On Determining, Imposing and Enforcing of the Fines to the Currency Exchange Operators and its Administrators” envisages a fine of 7,000 (Seven Thousand) GEL, for each fact of violation. Total – 133,000 (one hundred thirty-three Thousand) GEL.

4 (four) case of failure to determine the essence of the client's activity, which under the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Points and Their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020. Article 3, Paragraph 3, Subparagraph "t" of the Penalty Rules, envisages a fine in the amount of 2,000 (two thousand) GEL, for each case. Total 8,000 (eight thousand) GEL;

Financial Penalty of 3,000 (Three thousand) Lari was imposed on Currency Exchange operator for failure to execute requirements of the Article 29 paragraph 2 of the Law of Georgia “on Facilitating the Suppression of Money Laundering and Terrorism Financing”. In particular, policy implemented by currency exchange operator related to internal control does not meet the requirements set by the legislation (as well as the guidelines of the National Bank). It fails to meet the requirements of the legislation and the National Bank's guidelines. which according to the Article 3, paragraph 3, point “i” of the Rule “On Determining, imposing and enforcing of the fines to the Currency Exchange bureau and its administrators” envisages a Fine of 3,000 (Three thousand) Lari.

Failure to comply with the requirements of the Article 27 paragraph 6 of the Law of Georgia “on Facilitating the Suppression of Money Laundering and Terrorism Financing”. The software system implemented in the currency exchange office for the purpose of promoting prevention of money laundering and financing of terrorism is operating with significant faults. In particular, it fails to detect suspicious/unusual/split transactions and the verification of persons in the sanctioned and politically active lists. which according to the Article 3, paragraph 2, point “e” of the Rule “On Determining, imposing and enforcing of the fines to the Currency Exchange bureau and its administrators” envisages a Fine of 10,000 (Ten thousand) Lari.

In Total Currency Exchange Operator - LTd „FIN” (I.N. 401953702) was fined with 172,000 (one hundred seventy-two thousand) GEL.