On the imposition of the monetary fine on the Brokerage Company JSC Galt & Taggart (I/N 211359206)
1. Due to the non-fulfillment of the obligation provided by Article 6 of the law of Georgia "On Facilitation of Prevention of Illicit Income Legalization", Article 10 of the law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism", Articles 5 and 51 of the rule established by the Order №6 of the Head of the Financial Monitoring Service of January 24, 2012 "On the Rule of Receiving, Systemizing, Processing and Transferring of Information by a Brokerage Company to the Financial Monitoring Service of Georgia" (Hereinafter – The Rule) – towards 27 (twenty seven) operations (transactions) carried out by 2 (two) natural persons and the beneficial owners of 3 (three) legal entities, is fined for each case of violation - in the amount of 500 (five hundred) Lari, in the total amount of 13 500 (thirteen thousand five hundred) Lari.
2. Due to the non-fulfillment of the obligation - The brokerage company is not in full compliance with the obligation related to the implementation of internal control and monitoring for the purpose of the prevention of money laundering and terrorist financing, as well as the adoption and observance of procedures and rules. Namely, the internal documents on clients’ risk assessment/assignment, elaborated by the brokerage company, are deficient, towards certain clients KYC questionnaires are incomplete and their identification documents are not renewed in a timely manner, based on their risk level – provided by Article 8 of the law of Georgia "On Facilitation of Prevention of Illicit Income Legalization", Article 29 of the law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism", Articles 4 of the Rule - the Brokerage Company JSC "Galt & Taggart" is fined in the amount of 5 000 (five thousand) Lari.
3. Due to 7 (seven) cases of submitting inaccurate information to the National Bank of Georgia on the money laundering and terrorist financing risk reporting file by the brokerage companies, provided by the "Manual of Off-site Supervision of Money Laundering and Terrorism Financing Risks of Brokerage Companies" ratified by the Order №48/04 of 5 May 2016 of the President of The National Bank of Georgia, the Brokerage Company JSC "Galt & Taggart" is fined for each case of violation - in the amount of 1 000 (one thousand) Lari, in the total amount of 7 000 (seven hundred) Lari.
4. Due to 1 (one) case of submitting inaccurate information to the group of on-site inspectors of the National Bank of Georgia, the Brokerage Company JSC "Galt & Taggart" is fined in the amount of 1 000 (thousand) Lari.
5. Due to 1 (one) case of repeatedly submitting inaccurate information to the group of on-site inspectors of the National Bank of Georgia, the Brokerage Company JSC "Galt & Taggart" is fined in the amount of 10 000 (ten thousand) Lari.
6. Due to the non-fulfillment of the obligation - The brokerage company is not equipped with the proper automatic software (electronic) system to detect suspicious, unusual transactions and provide automatic verification in the lists of politically active and sanctioned persons – provided by Articles 7 and 8 of the law of Georgia "On Facilitation of Prevention of Illicit Income Legalization", paragraph 6 of Article 27 of the law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism", paragraph 5 of Articles 8 of the Rule - the Brokerage Company JSC "Galt & Taggart" is fined in the amount of 20 000 (twenty thousand) Lari.
The Brokerage company JSC "Galt & Taggart" is fined in the total amount of 56 500 (fifty six thousand five hundred) Lari.