1. The Loan Issuing Entity submitted the initial regxstration form to the Financial Monitoring Service late. The Loan Issuing Entity was registered with the National Bank of Georgia on June 24, 2022. According to Article 1, Paragraph 3 of Order No. 1, issued on June 5, 2020, by the Head of the Financial Monitoring Service of Georgia, titled "On the Approval of Rules on Record-Keeping, Storage, and Reporting of Information on Transactions by Obligated Entities to the Financial Monitoring Service of Georgia," any obligated entity that commences operations after the enactment of this order must submit the completed registration form to the Financial Monitoring Service of Georgia no later than 10 business days after obtaining a license, registration, or permit from the supervisory authority. The Loan Issuing Entity, LTD "Moniva Georgia," submitted the initial registration form to the Financial Monitoring Service late. This action constitutes a violation under Article 2¹, Paragraph 2, Sub-paragraph "a" of the "Rules for Determining, Imposing, and Enforcing Monetary Fines for Loan Issuing Entities," approved by Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, which provides for a monetary fine of 5,000 (five thousand) GEL.
2. A single instance of incorrect submission of information/documentation by the Loan Issuing Entity during the inspection process to the National Bank of Georgia constitutes a violation. According to Article 2¹, Paragraph 3, Sub-paragraph "n" of the "Rules for Determining, Imposing, and Enforcing Monetary Fines for Loan Issuing Entities," approved by Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, this violation entails a monetary fine in the amount of 2,000 (two thousand) GEL.
3. The assignment or reassessment of a risk level to a client by the Loan Issuing Entity without taking into account the relevant risk factors determined by Georgian legislation, including the legal acts of the National Bank of Georgia on risk assessment, and/or the internal policies/procedures of the Loan Issuing Entity, constitutes a violation. Specifically, three (3) instances of such improper risk assignment/reassessment were identified. According to Article 2¹, Paragraph 3, Sub-paragraph "v" of the "Rules for Determining, Imposing, and Enforcing Monetary Fines for Loan Issuing Entities," approved by Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, each such violation entails a monetary fine of 2,000 (two thousand) GEL per client. As a result, the total fine amounts to 6,000 (six thousand) GEL.
4. Five (5) instances of incorrect submission of information regarding money laundering and terrorism financing risk reporting to the National Bank of Georgia by the Loan Issuing Entity were identified. According to Article 2¹, Paragraph 4, Sub-paragraph "g" of the "Rules for Determining, Imposing, and Enforcing Monetary Fines for Loan Issuing Entities," approved by Order No. 218/04 of the President of the National Bank of Georgia, dated September 27, 2018, each violation entails a monetary fine of 1,000 (one thousand) GEL. Therefore, the total fine amounts to 5,000 (five thousand) GEL.

In total, the Loan Issuing Entity „MONIVA GEORGIA“ LLC (identification number 400330165) was fined 18,000 (eighteen thousand) GEL.