THE MONETARY FINE WAS IMPOSED ON CURRENCY EXCHANGE OPERATOR LLC Cash Point (I.D 400382545)

Under the Article 6, Paragraph 4, of the Rule Financial Monitoring Service of Georgia dated June 5, 2020, during the inspection, there was revealed 1 (one) case of failure to report transaction (CTR) to the Financial Monitoring Service, which under the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Points and Their Administrators” approved by Order No. 17/04 of the President of the National Bank of Georgia dated February 5, 2020. Article 3, paragraph 3, subparagraph “L” envisages a fine of 2,000 (two thousand) GEL, for each case. Total – 2,000 (two thousand) GEL.

4 (four) case of failure to investigate the origin of the transaction funds, which under the Article 3, Paragraph 3, sub-paragraph ‘z’ of the Rules Approved by the Decree N17/04 of the President of the National Bank of Georgia on February 5, 2020 (a version adopted after 2021, 5 April amendment) “On Determining, imposing and enforcing of the fines to the Currency Exchange bureau and its administrators” envisages a fine of GEL 3,000 (Three thousand) Lari on each case of infringement.

Financial Penalty of 3,000 (Three thousand) Lari was imposed on Currency Exchange operator for failure to execute requirements of the Article 29 paragraph 2 of the Law of Georgia “on Facilitating the Suppression of Money Laundering and Terrorism Financing”. In particular, policy implemented by currency exchange operator related to internal control does not meet the requirements set by the legislation (as well as the guidelines of the National Bank). It fails to meet the requirements of the legislation and the National Bank's guidelines. which according to the Article 3, paragraph 3, point “i” of the Rule “On Determining, imposing and enforcing of the fines to the Currency Exchange bureau and its administrators” envisages a Fine of 3,000 (Three thousand) Lari.

Failure to comply with the requirements of the Article 27 paragraph 6 of the Law of Georgia “on Facilitating the Suppression of Money Laundering and Terrorism Financing”. The software system implemented in the currency exchange office for the purpose of promoting prevention of money laundering and financing of terrorism is operating with significant faults. In particular, it fails to detect suspicious/unusual transactions. which according to the Article 3, paragraph 2, point “e” of the Rule “On Determining, imposing and enforcing of the fines to the Currency Exchange bureau and its administrators” envisages a Fine of 10,000 (Ten thousand) Lari.

Financial Penalty of 1,000 (Thousand) Lari was imposed on the Currency Exchange operator for failure to report accurate information to the National Bank of Georgia under the provisions of the “Rules on filing and submitting illicit income legalization and Terrorism Financing Risk Supervision Reports by Currency Exchange bureau”, which under the Article 3, Paragraph 4, sub-paragraph ‘d’ of the Rules Approved by the Decree N17/04 of the President of the National Bank of Georgia on February 5, 2020 (a version adopted after 2021, 5 April amendment) “On Determining, imposing and enforcing of the fines to the Currency Exchange bureau and its administrators” envisages a fine of GEL 1,000 (Thousand) Lari on each case of infringement.

In Total Currency Exchange Operator LLC Cash Point (I.D 400382545) was fined with – 28,000 (Twenty-eight thousand) GEL.