On the imposition of Monetary Fine to the Currency Exchange Office Ltd “M+” (Identification number: 405286088)

1. As of the date of commencement of the inspection, 2 (two) facts were revealed, 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 Fines Rules, it envisages a fine of 300 (three hundred) GEL for each violation, in total 600 (six hundred) GEL;
2. As of the date of commencement of the inspection determined by the legal act of the National Bank regarding the inspection of the currency exchange office, there was one instance of failure to submit reporting to the Financial Monitoring Service, as required under Paragraph 4 of Article 6 of the Rule “On Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia,” approved by Order №1 of June 5, 2020 of the Head of the Financial Monitoring Service of Georgia, In accordance with Subparagraph “l” of Paragraph 3 of Article 3 of the Fines Rule, this envisages a fine in the amount of 2,000 (two thousand) GEL for each violation. In total, 2,000 (two thousand) GEL;
3. 28 (Twenty-eight) facts of the failure by the currency exchange office to record information about the client and operations (transactions) through a special software (electronic) system, which, in accordance with article 3, paragraph 2, subparagraph "k" of the Rule “On Determining, Imposing and Enforcing of the Fines to the Currency Exchange Operators and its Administrators” approved by Order №17/04 of the President of the National Bank of Georgia dated February 5, 2020, this envisages a fine of 7,000 (seven thousand) GEL for each fact of violation, in total 196,000 (one hundred ninety-six thousand) GEL;
4. 1 (one) case of failure to determine the Nature of 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 2,000 (two thousand) GEL
5. Failure to comply with the requirements set forth in article 29, paragraphs one and 2 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”. The currency exchange office has not developed internal instructions, which, in accordance with article 3, paragraph 3, subparagraph “i” of the Rule “On Determining, Imposing and Enforcing of the Fines to the Currency Exchange Operators and its Administrators" approved by Order №17/04 of the President of the National Bank of Georgia dated February 5, 2020, it envisages a fine of 3,000 (three thousand) GEL;
6. 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/split transactions and automatic verification of individuals against the lists of sanctioned and politically exposed persons, which, in accordance with article 3, paragraph 2, subparagraph "e" of the Rule “On Determining, Imposing and Enforcing of the Fines to the Currency Exchange Operators and its Administrators” approved by Order №17/04 of the President of the National Bank of Georgia dated February 5, 2020, it envisages a fine of 10,000 (ten thousand) GEL.

Currency Exchange Office Ltd “M+” (Identification number: 405286088) was imposed a fine in the total amount of 213,600 (two hundred thirteen thousand six hundred) GEL.