The Loan Issuing entity submitted the initial registration form to the Financial Monitoring Service of Georgia with a delay. The Loan Issuing entity was registered at the National Bank of Georgia on March 1, 2019. According to Article 1, Paragraph 2 of the Order №1 issued on June 5, 2020, by the Head of the Financial Monitoring Service of Georgia, titled “On the Approval of the Rules for Record-Keeping, Storage, and Submission of Information on Transactions by Obligated Entities to the Financial Monitoring Service of Georgia,” any obligated entity who started their activities before the implementation of this order was required to submit the completed registration form to the Financial Monitoring Service of Georgia no later than one month after the order’s implementation. The obligated entity was supposed to submit the appropriate registration form to the Financial Monitoring Service of Georgia by November 20, 2020. However, the lending entity submitted the initial registration form on January 20, 2021. As a result, it is determined that the Loan Issuing entity, LLC “T-N Gold” (Identification Number: 404571414), submitted the registration form with a delay. Which according to the Article 2¹, Paragraph 2, Sub-paragraph "A" of the "Rule for Determining, Imposing, and Enforcing the Amount of Monetary Fines to the Loan Issuing Entities," approved by the Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, considers fining The Loan Issuing entity with the amount of 5,000 (five thousand) GEL.

During the inspection process, the Loan Issuing entity submitted information/documentation to the National Bank of Georgia incorrectly in two (2) instances. Which according to the Article 2¹, Paragraph 3, Sub-paragraph "N" of the "Rules for Determining, Imposing, and Enforcing the Amount of Monetary Fines to the Loan Issuing Entities," approved by the Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, considers fining The Loan Issuing entity with the amount of 2,000 (two thousand) GEL on each case. In total, for 2 (two) cases of violation mentioned in this paragraph - 4,000 (four thousand) GEL.

The software (electronic) system implemented in the Loan Issuing entity operates with significant deficiencies. Specifically, it lacks the functionality to identify suspicious, unusual, related (fragmented) deals and interconnected persons. Furthermore, during the testing process, the system failed to automatically identify/block all sanctioned individuals/ legal entities. Which according to the Article 2¹, Paragraph 2, Sub-paragraph "E" of the "Rules for Determining, Imposing, and Enforcing the Amount of Monetary Fines to the Loan Issuing Entities," approved by the Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, considers fining The Loan Issuing entity with the amount of 15,000 (fifteen thousand) GEL.

The Loan Issuing entity was identified failing to determine the nature of business activity for one client. Which according to the Article 2¹, Paragraph 3, Sub-paragraph "T" of the "Rules for Determining, Imposing, and Enforcing the Amount of Monetary Fines to the Loan Issuing Entities," approved by the Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, considers fining The Loan Issuing entity with the amount of 2,000 (two thousand) GEL on each case. In total, for 1 (one) case of violation mentioned in this paragraph - 2,000 (two thousand) GEL.

The Loan Issuing entity provided services to a client without determining the ownership and management (control) structure of the client. Which according to the Article 2¹, Paragraph 3, Sub-paragraph "A" of the "Rules for Determining, Imposing, and Enforcing the Amount of Monetary Fines to the Loan Issuing Entities," approved by the Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, considers fining The Loan Issuing entity with the amount of 1,000 (one thousand) GEL for each case. In total, for 1 (one) case of violation mentioned in this paragraph - 1,000 (one thousand) GEL.

The Loan Issuing entity submitted incorrect information to the National Bank of Georgia regarding the supervision of money laundering and terrorism financing risks on two (2) cases. Which according to the Article 2¹, Paragraph 4, Sub-paragraph "G" of the "Rules for Determining, Imposing, and Enforcing the Amount of Monetary Fines to the Loan Issuing Entities," approved by the Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, considers fining The Loan Issuing entity with the amount of 1,000 (one thousand) GEL for each case. In total, for 2 (two) case of violation mentioned in this paragraph - 2,000 (two thousand) GEL.

In total, The Loan Issuing Entity LLC “T-N Gold” (Identification Number: 404571414) was fined with amount of 29,000 (Twenty-nine thousand) GEL