A total of 5,514,000 (five million five hundred and fourteen thousand) GEL was fined to the Currency Exchange Office LTD „VALUTA+”.
The currency exchange office did not submit the initial registration form to the Financial Monitoring Service within the established deadlines. Failure to submit the initial registration form provided for in Article 1, Paragraph 3 of Order No. 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020 “Rules for Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia”, which, in accordance with Article 3, Paragraph 2, Subparagraph “a” of the “Rules for Determining, Imposing and Enforcing the Amount of Monetary Fines against Currency Exchange Offices and their Administrators” (hereinafter “Penalty Rules”) approved by Order No. 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;
As of the date of commencement of the inspection, has been revealed 2 (two) facts of failure to submit the transaction reports (CTR) to the Financial Monitoring Service of Georgia defined by Article 6, Paragraph 4 of the “Rules for Recording, Storing and Submitting Information on Transactions by an Obliged Entity to the Financial Monitoring Service of Georgia” approved by Order № 1 of the Head of the Financial Monitoring Service of Georgia dated June 5, 2020, which, in accordance with Article 3, Paragraph 3, Subparagraph “l” of the Penalty Rules, it envisages a fine of 2 000 (two thousand) GEL for each violation, in total 4,000 (four thousand) GEL;
453 (four hundred and fifty-three) facts of failure by a currency exchange office to record information about the client and operations (transactions) through a special software (electronic) system, which, in accordance with Article 3, Paragraph 2, Subparagraph "k" of the Penalty Rules, it envisages a fine of 7,000 (seven thousand) GEL for each fact of violation, in total 3,171,000 (three million one hundred and seventy-one thousand) GEL;
2,267 (two thousand two hundred and sixty-seven) cases of providing services to persons without verification, which, in accordance with Article 3, Paragraph 3, Subparagraph “b” of the Penalty Rules, it envisages a fine of 1,000 (one thousand) GEL for each fact of violation, in total 2,267,000 (two million two hundred and sixty-seven thousand) GEL;
In the case of 108 (one hundred and eight) operations (transactions) has been revealed the facts of failure to record the relevant information/documentation for the verification of the person acting on behalf of the client, which, in accordance with Article 3, Paragraph 4, Subparagraph "b" of the Penalty Rules, it envisages a fine of 500 (five hundred) GEL for each fact of violation, in total 54,000 (fifty-four thousand) GEL;
Failure to comply with the requirements set forth in Article 29, Paragraphs 1 and 2 of the Law of Georgia “On Facilitating the Prevention of Money Laundering and the Financing of Terrorism”. In particular, the document of internal control is characterized by significant gaps, it cannot meet the requirements defined by the legislation (as well as the guidelines of the National Bank of Georgia), which, in accordance with Article 3, Paragraph 3, Subparagraph “i” of the Penalty Rules, it envisages a fine of 3,000 (three thousand) GEL;
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 related transactions and the interconnected persons and verification of all individuals and legal entities in the lists of sanctioned and politically exposed persons, which, in accordance with Article 3, Paragraph 2, Subparagraph "e" of the Penalty Rules, it envisages a fine of 10,000 (ten thousand) GEL;
2 (two) facts of submitting incorrect information to the National Bank of Georgia by a currency exchange office in the reporting of money laundering and terrorist financing risk supervision, which, in accordance with Article 3, Paragraph 4, Subparagraph “d” of the Penalty Rules, it envisages a fine of 1,000 (one thousand) GEL for each fact of violation, in total 2,000 (two thousand) GEL.
