On the imposition of Monetary Fine to the Currency Exchange Office Ltd “Saba & Luka” (Identification number: 200000756)

1. 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”. In particular, the currency exchange office fails to ensure the fulfillment of obligations related to the implementation of internal control and monitoring for the purposes of preventing money laundering and 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;
2. 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/disjointed transactions and automatic verification of individuals in the lists of sanctioned and politically exposed persons. In addition, the program is not able to record information required by the Know Your Customer (KYC) standard, 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 "Saba & Luka" (identification number: 200000756) was imposed a fine in the total amount of 13,000 (thirteen thousand) GEL.