On Imposing a Financial Sanction on the Brokerage Company – LTD "Fidelis wealth management" (I/N 405214726)

6 (Six) fact of non-fulfillment of the Article 18 paragraph 1 sub-paragraph “d” of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism” and Article 4 paragraph 2 sub-paragraph “d” of the Manual Approved by the Decree №4/04 of the President of the National Bank of Georgia on January 12, 2021 “On Implementation of Preventive Measures”. In particular, the brokerage company did not obtain permission from the management of the financial institution to establish and/or to continue business relationship with 6 (Six) high-risk client. Which under the Article 5¹, Paragraph 3, sub-paragraph “d” of the Rule Approved by the Decree N35/04 (a version after amendment made on April 05, 2021) of the President of the National Bank of Georgia on February 14, 2012 “ On Determining, Imposing and Enforcing the Amount of Fines for Violations of the Securities’ Legislation, the Law of Georgia "On Accounting, Reporting and Auditing" and the law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism” against Entities and Members of their Governing Body” envisages a fine of 2 000 (Two Thousand) GEL for each fact of violation. Total – 12 000 (Twelve Thousand) GEL.

6 (Six) fact of non-fulfillment of the Article 18 paragraph 1 sub-paragraph “a” and Article 4 paragraph 2 sub-paragraph “a” of the Manual Approved by the Decree №4/04 of the President of the National Bank of Georgia on January 12, 2021 “On Implementation of Preventive Measures”. In particular, in relation to 6 (Six) high-risk client, the brokerage company did not study the client's business, source of wealth and source of funds. Which under the Article 5¹, Paragraph 3, sub-paragraph “g” of the Rule Approved by the Decree N35/04 (a version after amendment made on April 05, 2021) of the President of the National Bank of Georgia on February 14, 2012 “ On Determining, Imposing and Enforcing the Amount of Fines for Violations of the Securities’ Legislation, the Law of Georgia "On Accounting, Reporting and Auditing" and the law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism” against Entities and Members of their Governing Body” envisages a fine of 3 000 (Three Thousand) GEL for each fact of violation. Total – 18 000 (Eighteen Thousand) GEL.

THE BROKERAGE COMPANY – LTD “FIDELIS WEALTH MANAGEMENT” (I/N 405214726) is fined in the total amount of 30 000 (Thirty Thousand) GEL.