As of the date of commencement of the inspection, has been revealed 7 (seven) facts of failure to submit transaction reports (CTR) to the Financial Monitoring Service of Georgia defined by Article 6, Paragraph 4 of the “Rules for Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia” approved by Order № 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020, which, in accordance with Article 3, Paragraph 3, Subparagraph “l” of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” (hereinafter “Penalty Rules”) approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020, it envisages a fine of 2,000 (two thousand) GEL for each violation, in total 14,000 (fourteen thousand) GEL;
As of the date of commencement of the inspection, has been revealed 2 (two) facts of delayed submission (up to 5 working days) of the transaction reports (CTR) defined by Article 6, Paragraph 4 of the “Rules for Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia” approved by Order № 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020, to the Financial Monitoring Service of Georgia, which, in accordance with Article 3, Paragraph 4, Subparagraph “a.a” of the Penalty Rules, it envisages a fine of 100 (one hundred) GEL for each violation, in total 200 (two hundred) GEL;
As of the date of commencement of the inspection, has been revealed 1 (one) facts of delayed submission (5 and more working days) of the transaction reports (CTR) defined by Article 6, Paragraph 4 of the “Rules for Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia” approved by Order № 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020, to the Financial Monitoring Service of Georgia, which, in accordance with Article 3, Paragraph 4, Subparagraph “a.b” of the Penaly Rules, it envisages a fine of 300 (three hundred) GEL for each violation, in total 300 (three hundred) GEL;
4 (four) case of failure to determine the essence of the client's activity, which, in accordance with Article 3, Paragraph 3, Subparagraph "t" of the Penalty Rules, it envisages a fine of 2,000 (two thousand) GEL in relation to each client, in total 8,000 (eight thousand) GEL;
Failure to comply with the requirements set forth in Article 29, Paragraphs 1 and 2 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”. In particular, the document of internal control that was submitted by the obliged entity is characterized by significant gaps, it cannot meet the requirements defined by the legislation (as well as the guidelines of the National Bank of Georgia), which, in accordance with Article 3, Paragraph 3, Subparagraph “i” of the Penalty Rules, it envisages a fine of 3,000 (three thousand) GEL;
Failure to comply with the requirements set forth in Article 27, Paragraph 6 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”. The software (electronic) system implemented in the currency exchange office for the purposes of preventing money laundering and financing of terrorism, functions with significant shortcomings. In particular, it fails to ensure the detection of suspicious/unusual related transactions and the interconnected persons, which, in accordance with Article 3, Paragraph 2, Subparagraph "e" of the Penalty Rules, it envisages a fine of 10,000 (ten thousand) GEL.
The Currency Exchange Office I.E. „Murman Sirabidze” (Personal Number: 61001010451) has been fined with a total amount of 35,500 (thirty-five thousand and five hundred) GEL.