10 (ten) facts of failure to provide information about monitored transactions (operations) to the Financial Monitoring Service of Georgia, in accordance with Article 6, Paragraph 1, Subparagraph ‘a’ of the ‘Rule on Record-keeping, Storage and Reporting of the Information on Transactions by Obliged Entities to the Financial Monitoring Service of Georgia,’ approved by Order No. 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020. Pursuant to Article 3, Paragraph 3, Subparagraph ‘m’ of the ‘Rule for Determining, Imposing and Enforcing of the Fine to the Microfinance Organizations and Their Administrators’ (hereinafter – the Fine Rule), this entails a fine of GEL 2,000 (two thousand) per violation. Total – GEL 20,000 (twenty thousand);

12 (twelve) facts of submitting information regarding monitored transactions (operations) to the Financial Monitoring Service of Georgia with a delay of 5 or more business days, in accordance with Article 6, Paragraph 1, Subparagraph ‘a’ of the Rule referenced above. Pursuant to Article 3, Paragraph 4, Subparagraph ‘a.b’ of the Fine Rule, this entails a fine of GEL 300 (three hundred) per violation. Total – GEL 3,600 (three thousand six hundred).

1 (one) case of incorrect submission of information/documentation to the National Bank of Georgia during the inspection period. Pursuant to Article 3, Paragraph 3, Subparagraph ‘p’ of the Fine Rule, this entails a fine of GEL 2,000 (two thousand). Total – GEL 2,000 (two thousand);

As of the inspection start date determined by the legal act of the National Bank of Georgia, 5 (five) clients did not have an assigned risk rating. Pursuant to Article 3, Paragraph 3, Subparagraph ‘g’ of the Fine Rule, this entails a fine of GEL 3,000 (three thousand) per client. Total – GEL 15,000 (fifteen thousand);

2 (two) cases were identified during the inspection period where the microfinance organization failed to implement the preventive measure stipulated in Article 10, Paragraph 4 of the Law of Georgia ‘On Facilitating the Prevention of Money Laundering and Terrorist Financing’ (hereinafter – the ‘Law’), specifically failing to determine the nature of the clients’ business. Pursuant to Article 3, Paragraph 3, Subparagraph ‘t’ of the Fine Rule, this entails a fine of GEL 2,000 (two thousand) per client. Total – GEL 4,000 (four thousand);

6 (six) instances of submission of incorrect information to the National Bank of Georgia in AML/CFT risk supervision reporting were identified during the inspection period. Pursuant to Article 3, Paragraph 4, Subparagraph ‘d’ of the Fine Rule, this entails a fine of GEL 1,000 (one thousand) per violation. Total – GEL 6,000 (six thousand);

During the inspection period, it was identified that the software (electronic) system of the microfinance organization, implemented to support the prevention of money laundering and terrorist financing, operated with significant deficiencies. Pursuant to Article 3, Paragraph 2, Subparagraph ‘e’ of the Fine Rule, this entails a fine of GEL 20,000 (twenty thousand). Total – GEL 20,000 (twenty thousand);

During the inspection period, it was identified that the internal control rules of the microfinance organization, active during the period under review, did not comply with the requirements established by legislation, specifically Article 29 of the Law of Georgia ‘On Facilitating the Prevention of Money Laundering and Terrorist Financing’ and the guidelines of the National Bank of Georgia. Pursuant to Article 3, Paragraph 3, Subparagraph ‘i’ of the Fine Rule, this entails a fine of GEL 5,000 (five thousand). Total – GEL 5,000 (five thousand);

4 (four) cases of failure to comply with the written requirements within the established timeframe, as issued following the inspection conducted on the basis of Decree №1036-1k of the President of the National Bank of Georgia dated November 10, 2023. Pursuant to Article 3, Paragraph 2, Subparagraph ‘i’ of the Fine Rule, this entails a fine of GEL 7,000 (seven thousand) per violation. Total – GEL 28,000 (twenty-eight thousand);

515 (five hundred and fifteen) cases were identified during the inspection period where the microfinance organization provided services to individuals without proper identification. Pursuant to Article 3, Paragraph 3, Subparagraph ‘b’ of the Fine Rule, this entails a fine of GEL 1,000 (one thousand) per violation. Total – GEL 515,000 (five hundred and fifteen thousand);

1 (one) case where the microfinance organization, in relation to a client, failed to comply with the requirement stipulated in Article 18, Paragraph 1, Subparagraph ‘e’ of the Law of Georgia, specifically failing to study the origin of the assets (funds) regarding the transactions. Pursuant to Article 3, Paragraph 3, Subparagraph ‘z’ of the Fine Rule, this entails a fine of GEL 3,000 (three thousand). Total – GEL 3,000 (three thousand).

Microfinance Organization LLC Bermeli (Identification number: 245431108) was imposed a fine. In the amount of 621,600 (six hundred twenty-one thousand six hundred) GEL.