1. Loan Issuing Entity submitted the initial registration form to the Financial Monitoring Service late. The Loan Issuing Entity was registered at the National Bank of Georgia on February 01, 2019. Under the article 1, paragraph 2 of the Order No. 1 of Head of Financial Monitoring Service of Georgia dated June 5, 2020 “On the Approval of Rules on Record–Keeping, Storage and Reporting of the Information on the Transaction by Obligated Entities to Financial Monitoring Service of Georgia”, “Insurance Broker, Reinsurance Broker, Loan Issuing Entity, lawyer, law firm, which had started its activities before the entry into force of this rule, should have submitted form to the Financial Monitoring Service of Georgia within 1 month from the entry into force of this rule. Loan Issuing Entity submitted the initial registration form to Financial Monitoring Service of Georgia on January 29, 2021. Respectively, has been revealed the delayed submission of the registration form to the Financial Monitoring Service of Georgia. In accordance with article 2¹, paragraph 2, sub-paragraph "a" of the "Rules for Determining, Imposing and Enforcing the Amount of 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, it envisages fine of 5,000 (five thousand) GEL.
2. During the inspection process, has been revealed 3 (three) cases of incorrect submission of information by the Loan Issuing Entity to the inspection group of the National Bank of Georgia, which in accordance with article 2¹, paragraph 3, sub-paragraph "n" of the "Rules for Determining, Imposing and Enforcing the Amount of Monetary Fine for Loan Issuing Entity" approved by Order №218/04 of the President of the National Bank of Georgia dated September 27, 2018, it envisages fine of 2,000 GEL for each case, In total – 6 000 (six thousand) GEL.
3. The electronic system implemented in the Loan Issuing Entity operates with significant flaws. Specifically, it lacks the functionality to detect suspicious or noteworthy signs, including the identification of fragmented transactions (deals), and the system of revealing/verifying individuals against the lists of sanctioned and politically exposed persons as required by the United Nations Security Council resolutions, as well as the instructions provided by the National Bank of Georgia. As a consequence, the system operates with severe failures, which in accordance with article 2¹, paragraph 2, subparagraph “e” of the "Rules for Determining, Imposing and Enforcing the Amount of 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, it envisages fine of 15,000 (fifteen thousand) GEL.

In total, Loan Issuing Entity LTD “Binobi” (Identification number: 204549417) was fined with 26,000 (twenty-six thousand) GEL.