"During an inspection period by the National Bank of Georgia, a microfinance organization incorrectly submitted information/documentation on 1 (one) occasion. According to the rule approved by the Order No. 16/04 of the President of the National Bank of Georgia dated February 5, 2020, titled 'On the Approval of the Rule for Determining, Imposing, and Enforcing Fines on Microfinance Organizations and Their Administrators' (hereinafter referred to as the 'Fine Rule'), Article 3, Paragraph 3, Subparagraph 'o', the microfinance organization is subject to a fine of 2,000 (two thousand) GEL for each violation. For the mentioned violation, for one instance, the total fine is 2,000 (two thousand) GEL.

The software (electronic) system implemented by the organization operates with significant deficiencies. It does not have a comprehensive system for automatically assigning risk according to the microfinance organization's policy, lacks the capability to detect unusual and suspicious transactions, and does not verify individuals (counterparties) against lists of sanctioned and politically exposed persons. According to Article 3, Paragraph 2, Subparagraph 'e' of the Fine Rule, this entails a fine of 20,000 GEL. The total fine is 20,000 (twenty thousand) GEL.

As a result of the inspection, a violation of the requirements stipulated in Article 9, Clause 2 of the "Rules for accounting, storage and submission of information on transactions by an accountable person to the Financial Monitoring Service of Georgia" approved by Order №1 of the Head of the Financial Monitoring Service of Georgia on June 5, 2020, In particular, for the Financial Monitoring Service of Georgia, 2 (two) cases of late submission of reports without meeting the established deadline (for a delay of up to five working days), which is provided for in accordance with the fine rule - Article 3, Clause 4, Sub-Clause "A", Sub-Clause "AA" to be fined - in the amount of 100 (one hundred) GEL for each violation. A total of 200 (two hundred) GEL for 2 (two) violation cases mentioned in this paragraph.

There were 2 (two) instances of failing to submit reports on suspicious transactions within the deadlines established by Article 9, Paragraph 1 of the 'Rule on Recording, Retaining, and Submitting Information on Transactions by Accountable Persons to the Financial Monitoring Service of Georgia,' approved by Order No. 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020. According to Article 3, Paragraph 2, Subparagraph 'b' of the Fine Rule, this violation entails a fine of 5,000 (five thousand) GEL for each instance. For the aforementioned violation, the total fine is 10,000 (ten thousand) GEL.

There were 17 (seventeen) instances of failing to submit information on operations/transactions subject to monitoring to the Financial Monitoring Service of Georgia, in accordance with Subparagraph 'a' of Paragraph 1, Article 6 of the 'Rule on Recording, Retaining, and Submitting Information on Transactions by Accountable Persons to the Financial Monitoring Service of Georgia,' approved by Order No. 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020. According to Article 3, Paragraph 3, Subparagraph 'l' of the Fine Rule, each of these violations entails a fine of 2,000 (two thousand) GEL. For the 17 (seventeen) instances mentioned in this paragraph, the total fine is 34,000 (thirty-four thousand) GEL

For the date of the inspection of the microfinance organization as determined by the legal act of the National Bank, 1 (one) client did not have an assigned risk rating. According to Article 3, Paragraph 3, Subparagraph 'c' of the Fine Rule, this entails a fine of 3,000 (three thousand) GEL for each such client. The total fine is 3,000 (three thousand) GEL

As of the start date of the inspection, the microfinance organization assigned/reassessed the risk for 1 (one) client without considering the relevant risk factors determined by Georgian legislation, including the legal acts of the National Bank regarding risk assessment and/or the internal policies/procedures of the microfinance organization. According to Article 3, Paragraph 3, Subparagraph 'f' of the Fine Rule, this entails a fine of 3,000 (three thousand) GEL for each such client. The total fine is 3,000 (three thousand) GEL

There were 14 (fourteen) instances of submitting inaccurate information to the National Bank of Georgia in reports as stipulated by the rule approved by Order No. 61/04 of the President of the National Bank of Georgia dated May 31, 2016, titled 'On the Approval of the Rule for Filling Out Supervision Reports on the Risk of Money Laundering and Terrorism Financing by Microfinance Organizations and Submitting Information. According to Article 3, Paragraph 4, Subparagraph 'd' of the Fine Rule, this entails a fine of 1,000 (one thousand) GEL for each violation. The total fine for these violations is 14,000 (fourteen thousand) GEL

MICROFINANCE ORGANIZATION – „MICROFINANCE ORGANIZATION CREDITSERVICE+“ JSC is fined in the total amount of 86,200 (eighty-six thousand two hundred) GEL.