2026-08-05 | 190/04Added
This Order approves the procedure for determining, imposing, and enforcing monetary fines against licensed securities registrars and brokerage companies for violations of anti-money laundering and counter-terrorist financing legislation. It categorizes violations into especially serious, serious, and less serious offenses, assigning specific fine amounts in Georgian Lari for each infraction, such as failure to submit reports, inadequate client identification, or non-compliance with sanctions regimes. The document also establishes increased fines for systematic violations and authorizes the National Bank of Georgia to impose a fine of up to 100,000 Lari or other measures for repeated breaches or systemic risks.
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Order of the President of the National Bank of Georgia No. 190/04 August 5, 2026 Tbilisi
On Approval of the Procedure for Determining, Imposing, and Enforcing Monetary Fines for Violations of the Legislation of Georgia on Combating Money Laundering and Financing of Terrorism by a Securities Registrar, a Brokerage Company, and a Member of Their Governing Body
On the basis of sub-paragraph "z" of paragraph 1 of Article 15, paragraphs 1, 3, and 4 of Article 48, and sub-paragraph "t" of Article 52 of the Organic Law of Georgia "On the National Bank of Georgia", Article 551 of the Law of Georgia "On the Securities Market", sub-paragraph "g" of Article 4, and paragraph 6 of Article 38 of the Law of Georgia "On Combating Money Laundering and Financing of Terrorism", I order:
Article 1
Approve the "Procedure for Determining, Imposing, and Enforcing Monetary Fines for Violations of the Legislation of Georgia on Combating Money Laundering and Financing of Terrorism by a Securities Registrar, a Brokerage Company, and a Member of Their Governing Body" in the attached edition.
Article 2
This Order shall enter into force from the moment of its publication.
Acting President of the National Bank of Georgia Ekaterine Mikabadze
Procedure for Determining, Imposing, and Enforcing Monetary Fines for Violations of the Legislation of Georgia on Combating Money Laundering and Financing of Terrorism by a Securities Registrar, a Brokerage Company, and a Member of Their Governing Body
Article 1. General Provisions
Article 2. Monetary Fines for a Brokerage Company for Violation of the Legislation of Georgia on Combating Money Laundering and Financing of Terrorism, Legal Acts Issued by the National Bank on Its Basis, Written Instructions, Requirements Determined as a Result of Inspection/Supervision, and/or Non-Compliance with Instructions of the Financial Monitoring Service
Violations caused by non-compliance with the Law of Georgia "On Combating Money Laundering and Financing of Terrorism", legal acts of the Financial Monitoring Service and the National Bank related to combating money laundering and financing of terrorism, requirements determined as a result of the National Bank's inspection/supervision, written instructions, and/or instructions of the Financial Monitoring Service are divided into the following categories:
a) Especially serious violations; b) Serious violations; c) Less serious violations.
Especially serious violations include the following violations and result in a fine for the brokerage company in the following amounts:
a) Failure to submit the primary registration form to the Financial Monitoring Service within the established deadlines – 5,000 (five thousand) Lari; b) Failure to submit a report on suspicious transactions to the Financial Monitoring Service within the established deadlines, as provided for by paragraph 3 of Article 3 and/or paragraph 1 of Article 4 of the "Procedure for Recording, Storing, and Submitting Information on Transactions by Accountable Persons to the Financial Monitoring Service" approved by Order No. 1 of the Head of the Financial Monitoring Service dated June 5, 2020 (hereinafter – the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service) – 5,000 (five thousand) Lari for each fact of violation; c) Non-compliance with the instruction of the Financial Monitoring Service on suspension of execution of a transaction (operation) – 5,000 (five thousand) Lari for each fact of violation; d) Non-compliance with the decision of the Governmental Commission on Issues of Implementation of Resolutions of the UN Security Council on Imposing Asset Freezes – 10,000 (ten thousand) Lari for each such freeze; e) Absence of a program (electronic) system or functioning with significant defects in a system that ensures the detection of alert/suspicious signs, including fragmented transactions (operations), and automatic verification of a person against lists of sanctioned persons provided for by political figures, UN Security Council resolutions, the Procedure for Implementation of Sanctions Regimes, and/or sanctions regimes determined by written instructions of the National Bank, for the purpose of ensuring compliance with requirements provided for by legislation on combating money laundering and financing of terrorism, the Procedure for Implementation of Sanctions Regimes approved by Order No. 208/04 of the President of the National Bank of Georgia dated August 4, 2023 (hereinafter – the Procedure for Implementation of Sanctions Regimes), Article 2, and/or sanctions regimes determined by written instructions of the National Bank – 20,000 (twenty thousand) Lari; f) Detection of transactions (operations) carried out in violation or circumvention of requirements provided for by UN Security Council resolutions, the Procedure for Implementation of Sanctions Regimes, and/or sanctions regimes determined by written instructions of the National Bank – 7,000 (seven thousand) Lari for each fact of violation; g) Failure to submit information/documentation required by each point of the agreement concluded between the parties during the inspection period of the brokerage company inspection to the National Bank before the expiration of the inspection period – 5,000 (five thousand) Lari for each fact of non-submission of information/documentation provided for by each point of the agreement; h) Obstruction of the inspection group by the brokerage company during the inspection period determined by the legal act of the National Bank on the
inspection of the brokerage company, which caused a delay in the implementation of the inspection – 10,000 (ten thousand) Lari; i) Non-compliance with written requirements determined for the brokerage company within the established deadlines as a result of remote inspection/supervision – 7,000 (seven thousand) Lari for each fact of non-compliance with the requirement; j) Non-compliance with written requirements determined for the brokerage company within the established deadlines as a result of on-site inspection – 7,000 (seven thousand) Lari for each fact of non-compliance with the requirement; k) Non-registration of information about a client and/or a transaction (operation) through a special program (electronic) system – 10,000 (ten thousand) Lari for each fact of violation; l) Failure to submit a report on suspicious transactions provided for by paragraph 3 of Article 3 and/or paragraph 1 of Article 4 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service to the Financial Monitoring Service by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company – 7,000 (seven thousand) Lari for each fact of violation.
Serious violations include the following violations and result in a fine for the brokerage company in the following amounts:
a) Provision of services to a person without determining the structure of ownership and control (control) of the client and/or without identification/verification of the beneficial owner – 1,000 (one thousand) Lari for each fact of violation; b) Provision of services to a person (including a person acting on behalf of a client) without identification/verification – 1,000 (one thousand) Lari for each fact of violation; c) The client does not have a risk level assigned by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company – 3,000 (three thousand) Lari for each such client; d) Non-updating of information about a person and/or failure to obtain permission from management to establish or continue a business relationship with a person (except for a politically exposed person) in accordance with the risk level, as well as in cases determined by legislation on combating money laundering and financing of terrorism and legal acts of the National Bank – 2,000 (two thousand) Lari for each such person; e) Violation of obligations provided for by legislation regarding a politically exposed person – 5,000 (five thousand) Lari for each such person; f) Assignment/re-assessment of risk to a client without taking into account corresponding risk factors determined by the legislation of Georgia, including legal acts of the National Bank on risk assessment, and/or internal policy/procedures of the brokerage company – 3,000 (three thousand) Lari for each such client; g) The brokerage company does not monitor the business relationship established with the client, study the nature of the transaction (operation), business, property, and/or origin of funds/virtual assets in accordance with legislation and/or internal policy/procedures – 3,000 (three thousand) Lari for each client; h) Failure to determine the essence of the client's activity and/or the purpose and intended nature of the business relationship – 2,000 (two thousand) Lari for each client; i) The brokerage company does not have developed internal control-related policies/procedures and/or instructions/rules, and/or the policies/procedures and/or instructions/rules developed/implemented by it do not meet the requirements determined by legislation and/or the National Bank – 5,000 (five thousand) Lari; j) Failure to submit a report on supervision of money laundering and terrorist financing risks to the National Bank within 30 calendar days after the expiration of the established deadline – 5,000 (five thousand) Lari; k) Detection of non-submission of reports provided for by paragraph 3 of Article 6 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service to the Financial Monitoring Service by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company, or submission of incorrect information held by the brokerage company –
2,000 (two thousand) Lari for each fact of violation; l) Submission of incorrect information held by the brokerage company when sending a report on suspicious transactions provided for by paragraph 3 of Article 3 and/or paragraph 1 of Article 4 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service to the Financial Monitoring Service by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company – 3,000 (three thousand) Lari for each incorrectly submitted report; m) Failure to submit information/documentation requested by the Financial Monitoring Service within the established deadline, or submission of incorrect documentation/information held by the brokerage company – 3,000 (three thousand) Lari for each fact of violation; n) Submission of information/documentation to the National Bank during the brokerage company inspection process with a delay beyond the deadline provided for by each point of the agreement concluded between the parties during the inspection period, and/or submission of incorrect information/documentation held by the brokerage company – 2,000 (two thousand) Lari for each fact of delay in submission of information/documentation provided for by each point of the agreement, and/or incorrect submission; o) Detection of submission of information on one or more monitored transactions/operations (except for suspicious transactions/operations) in one report provided for by the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company – 3,000 (three thousand) Lari for each transaction (operation) subject to the report; p) A member of the governing body of the brokerage company who fails to ensure compliance with obligations related to the implementation and functioning of a compliance control system for the purposes of combating money laundering and financing of terrorism by the brokerage company, and/or compliance with written instructions of the National Bank and/or requirements determined by the National Bank, shall be fined – 5,000 (five thousand) Lari.
Less serious violations include the following violations and result in a fine for the brokerage company in the following amounts:
a) Detection of submission of reports provided for by paragraph 3 of Article 6 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service to the Financial Monitoring Service by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company with a violation of the established deadline, late submission:
a.a) For a delay of up to 5 working days – 100 (one hundred) Lari; a.b) For a delay of 5 or more working days – 300 (three hundred) Lari; b) Detection of violation of established requirements for recording information/documentation about persons (including persons acting on behalf of clients) and/or their beneficial owners, identification and/or verification, transactions (operations) carried out by them, and/or storage of information/documentation provided for by Article 27 of the Law of Georgia "On Combating Money Laundering and Financing of Terrorism" – 500 (five hundred) Lari for each fact of violation; c) Detection of submission of information and documents requested by the Financial Monitoring Service by the date of commencement of the inspection determined by the legal act of the National Bank on the inspection of the brokerage company with a violation of the established deadline:
c.a) For a delay of up to 5 working days – 100 (one hundred) Lari; c.b) For a delay of 5 or more working days – 300 (three hundred) Lari; d) Submission of incorrect information to the National Bank by the brokerage company in the report on supervision of money laundering and terrorist financing risks – 1,000 (one thousand) Lari for each fact of violation; e) Submission of reports on supervision of money laundering and terrorist financing risks by the brokerage company to the National Bank with a delay of up to 30 calendar days – 2,000 (two thousand) Lari; f) Submission of incorrect and/or incomplete information/documentation requested by the National Bank (except for information/documentation requested within the framework of inspection) – 1,000 (one thousand) Lari for each fact of violation.
Violations provided for in this paragraph are granted the status of systematic violations by the National Bank and result in a fine for the brokerage company in the following amounts:
a) Repeated non-submission of a report on supervision of money laundering and terrorist financing risks to the National Bank by the brokerage company, if the brokerage company has already been fined in accordance with sub-paragraph "k" of paragraph 3 of this Article, results in a fine – 10,000 (ten thousand) Lari for each unsubmitted report; b) Submission of a report on supervision of money laundering and terrorist financing risks to the National Bank by the brokerage company with a delay of up to 30 days, if the brokerage company has already been fined in accordance with sub-paragraph "e" of paragraph 4 of this Article, results in a fine – 4,000 (four thousand) Lari for each late-submitted report; c) Repeated non-compliance with written requirements determined within the established deadlines as a result of remote inspection/supervision – 14,000 (fourteen thousand) Lari for each fact of detection of non-compliance with the requirement; d) Repeated non-compliance with written requirements determined for the brokerage company within the established deadlines as a result of on-site inspection – 14,000 (fourteen thousand) Lari for each fact of detection of non-compliance with the requirement; e) Repeated fact of non-registration of information about a client and/or operations (transactions), if the brokerage company has already been fined in accordance with sub-paragraph "l" of paragraph 2 of this Article – 20,000 (twenty thousand) Lari for each fact of violation; f) Repeated provision of services to the same person without determining the structure of ownership and control (control) of the client and/or without identification/verification of the beneficial owner, if the brokerage company has already been fined in accordance with sub-paragraph "a" of paragraph 3 of this Article regarding this person – 2,000 (two thousand) Lari for each fact of violation; g) Repeated provision of services without identification/verification of the same client (and/or a person acting on behalf of the client), if the brokerage company has already been fined in accordance with sub-paragraph "b" of paragraph 3 of this Article regarding this person – 2,000 (two thousand) Lari for each fact of violation.
If, as a result of the inspection of the brokerage company, a violation is again detected for which a sanction provided for in paragraph 5 of this Article has already been applied to the brokerage company once, and/or certain violations create a systemic risk of money laundering and financing of terrorism for the brokerage company, the National Bank is authorized to fine the brokerage company in the amount of 100,000 (one hundred thousand) Lari and/or apply other measures provided for by legislation.
Article 3. Monetary Fines for a Securities Registrar for Violation of the Legislation of Georgia on Combating Money Laundering and Financing of Terrorism, Legal Acts Issued by the National Bank on Its Basis, Written Instructions, Requirements Determined as a Result of Inspection/Supervision, and/or Non-Compliance with Instructions of the Financial Monitoring Service
Violations caused by non-compliance with the Law of Georgia "On Combating Money Laundering and Financing of Terrorism", legal acts of the Financial Monitoring Service and the National Bank related to combating money laundering and financing of terrorism, requirements determined as a result of the National Bank's inspection/supervision, written instructions, and/or instructions of the Financial Monitoring Service are divided into the following categories:
a) Especially serious violations; b) Serious violations; c) Less serious violations.
Especially serious violations include the following violations and result in a fine for the securities registrar in the following amounts:
a) Failure to submit the primary registration form to the Financial Monitoring Service within the established deadlines – 3,000 (three thousand) Lari; b) Failure to submit a report on suspicious transactions to the Financial Monitoring Service within the established deadlines, as provided for by paragraph 3 of Article 3 and/or paragraph 1 of Article 4 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service – 3,000 (three thousand) Lari for each fact of violation; c) Non-compliance with the instruction of the Financial Monitoring Service on suspension of execution of a transaction (operation) – 5,000 (five thousand) Lari for each fact of violation; d) Non-compliance with the decision of the Governmental Commission on Issues of Implementation of Resolutions of the UN Security Council on Imposing Asset Freezes – 7,000 (seven thousand) Lari for each such freeze; e) Absence of a program (electronic) system or functioning with significant defects in a system that ensures the detection of alert/suspicious signs, including fragmented transactions (operations), and automatic verification of a person against lists of sanctioned persons provided for by political figures, UN Security Council resolutions, the Procedure for Implementation of Sanctions Regimes, and/or sanctions regimes determined by written instructions of the National Bank, for the purpose of ensuring compliance with requirements provided for by legislation on combating money laundering and financing of terrorism, Article 2 of the Procedure for Implementation of Sanctions Regimes, and/or sanctions regimes determined by written instructions of the National Bank – [Text cuts off here]
(Operations) detection and automatic verification of a person in the lists of sanctioned persons provided for by sanction regimes determined by the resolutions of the UN Security Council and the procedure for compliance with sanction regimes and/or written instructions of the National Bank (absence of such persons or significant defects in functioning) – 10,000 (ten thousand) GEL;
v) Detection of operations (transactions) carried out in violation or circumvention of requirements provided for by sanction regimes determined by the resolutions of the UN Security Council and/or by written instructions of the National Bank regarding compliance with sanction regimes – 5,000 (five thousand) GEL for each instance of violation;
z) Failure to submit information/documentation required by each clause of the agreement concluded between the parties during the inspection period of the Securities Registrar’s inspection to the National Bank before the deadline – 3,000 (three thousand) GEL for each instance of failure to submit information/documentation provided for by each clause of the agreement;
t) Obstruction of the inspection group by the Securities Registrar during the inspection period defined by the legal act of the National Bank regarding the inspection, which caused a delay in the inspection – 7,000 (seven thousand) GEL;
i) Non-compliance with written requirements defined for the Securities Registrar within the established deadline as a result of remote inspection/supervision – 5,000 (five thousand) GEL for each instance of non-compliance;
k) Non-compliance with written requirements defined for the Securities Registrar within the established deadlines as a result of on-site inspection – 5,000 (five thousand) GEL for each instance of non-compliance;
l) Failure to register information about the client and/or transaction (operation) through the special software (electronic) system – 7,000 (seven thousand) GEL for each instance of violation;
m) Failure to submit to the Financial Monitoring Service a report on suspicious transactions provided for by paragraph 3 of Article 3 and/or paragraph 1 of Article 4 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service for the date of commencement of the inspection defined by the legal act of the National Bank regarding the inspection of the Securities Registrar – 5,000 (five thousand) GEL for each instance of violation.
a) Provision of services to a person without determining the structure of ownership and management (control) of the client and/or without identification/verification of the beneficial owner – 1,000 (one thousand) GEL for each instance of violation;
b) Provision of services to a person (including a person acting on behalf of the client) without identification/verification – 1,000 (one thousand) GEL for each instance of violation;
c) The client does not have a risk level assigned by the date of commencement of the inspection defined by the legal act of the National Bank regarding the inspection of the Securities Registrar – 2,000 (two thousand) GEL for each such client;
d) Failure to update information about the person and/or failure to obtain permission from management to establish or continue a business relationship with the person (excluding politically exposed persons) in cases determined by legislation on combating money laundering and financing of terrorism and legal acts of the National Bank corresponding to the risk level – 2,000 (two thousand) GEL for each such person;
e) Violation of obligations provided for by legislation regarding a politically exposed person – 3,000 (three thousand) GEL for each such person;
f) Assignment/re-assessment of risk to the client without taking into account the corresponding risk factors defined by the legislation of Georgia, including the legal act of the National Bank on risk assessment and/or the internal policy/procedures of the Securities Registrar – 2,000 (two thousand) GEL for each such client;
z) The Securities Registrar does not monitor the business relationship established with the client, study the transaction (operation), activity, property and/or origin of funds/virtual assets in accordance with legislation and/or internal policy/procedures – 2,000 (two thousand) GEL for each client;
t) Failure to determine the essence of the client’s activity and/or the purpose and intended nature of the business relationship – 2,000 (two thousand) GEL for each client;
i) The Securities Registrar has not developed internal control policies/procedures and/or instructions/rules, or the policies/procedures and/or instructions/rules developed/implemented by it do not meet the requirements defined by legislation and/or the National Bank – 3,000 (three thousand) GEL;
k) Failure to submit the report on supervision of money laundering and financing of terrorism risks to the National Bank within 30 calendar days from the expiration of the deadline established for such reporting – 3,000 (three thousand) GEL;
l) Incorrect presentation of information available to the Securities Registrar when sending a report on suspicious transactions provided for by paragraph 3 of Article 3 and/or paragraph 1 of Article 4 of the Procedure approved by Order No. 1 of the Head of the Financial Monitoring Service to the Financial Monitoring Service by the date of commencement of the inspection defined by the legal act of the National Bank regarding the inspection of the Securities Registrar – 3,000 (three thousand) GEL for each incorrectly submitted report;
m) Failure to submit information/documentation requested by the Financial Monitoring Service within the established deadlines or incorrect presentation of documentation/information available to the Securities Registrar – 3,000 (three thousand) GEL for each instance of violation;
n) Submission of information/documentation to the National Bank during the Securities Registrar’s inspection with a delay in the deadline provided for by each clause of the agreement concluded between the parties and/or incorrect presentation of information/documentation available to the Securities Registrar – 2,000 (two thousand) GEL for each instance of delay or incorrect presentation of information/documentation provided for by each clause of the agreement;
o) A member of the governing body of the Securities Registrar who fails to ensure compliance with obligations related to the implementation and functioning of the compliance control system for the purposes of combating money laundering and financing of terrorism by the Securities Registrar and/or compliance with written instructions of the National Bank and/or requirements defined by the National Bank – 3,000 (three thousand) GEL.
a) Detection of violation of established requirements for determining persons (including persons acting on behalf of the client) and/or their beneficial owners, identification/verification, recording of information/documentation on operations (transactions) carried out by them, and/or storage of other information/documentation defined by Article 27 of the Law of Georgia “On Combating Money Laundering and Financing of Terrorism” – 500 (five hundred) GEL for each instance of violation;
b) Detection of failure to submit information and documents requested by the Financial Monitoring Service by the established deadline by the date of commencement of the inspection defined by the legal act of the National Bank regarding the inspection of the Securities Registrar, for each instance of violation:
b.a) Delay of up to 5 working days – 100 (one hundred) GEL;
b.b) Delay of 5 or more working days – 300 (three hundred) GEL;
c) Submission of incorrect information to the National Bank by the Securities Registrar in the report on supervision of money laundering and financing of terrorism risks – 1,000 (one thousand) GEL for each instance of violation;
d) Submission of the report on supervision of money laundering and financing of terrorism risks by the Securities Registrar to the National Bank with a delay of up to 30 calendar days – 1,000 (one thousand) GEL;
e) Incorrect and/or incomplete submission of information and documents requested by the National Bank (excluding information/documentation requested within the framework of inspection) – 1,000 (one thousand) GEL for each instance of violation.
a) Repeated failure to submit the report on supervision of money laundering and financing of terrorism risks to the National Bank by the Securities Registrar, if the Securities Registrar has already been fined under paragraph “k” of sub-paragraph 3 of this article, results in a fine of 6,000 (six thousand) GEL for each report not submitted;
b) Submission of the report on supervision of money laundering and financing of terrorism risks by the Securities Registrar to the National Bank of Georgia with a delay of up to 30 days, if the Securities Registrar has already been fined under paragraph “d” of sub-paragraph 4 of this article, results in a fine of 2,000 (two thousand) GEL for each report submitted with delay;
c) Repeated non-compliance with written requirements defined as a result of remote inspection/supervision within the established deadline – 10,000 (ten thousand) GEL for each instance of non-compliance detected;
d) Repeated non-compliance with written requirements defined for the Securities Registrar within the established deadlines as a result of on-site inspection – 10,000 (ten thousand) GEL for each instance of non-compliance detected;
e) Repeated failure to register information about the client and/or transactions (operations), if the Securities Registrar has already been fined under paragraph “l” of sub-paragraph 2 of this article – 14,000 (fourteen thousand) GEL for each instance of violation;
f) Repeated provision of services to the same person without determining the structure of ownership and management (control) of the client and/or without identification/verification of the beneficial owner, if the Securities Registrar has already been fined for this person under paragraph “a” of sub-paragraph 3 of this article – 2,000 (two thousand) GEL for each instance of violation;
z) Repeated provision of services to the same client (and/or person acting on behalf of the client) without identification/verification, if the Securities Registrar has already been fined for this person under paragraph “b” of sub-paragraph 3 of this article – 2,000 (two thousand) GEL for each instance of violation.
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Source: National Bank of Georgia — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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