Who Article 165 is addressed to
Article 165 of the Georgian Code of Administrative Offences has one specific addressee: banks and other financial and credit institutions. It regulates two closely connected duties — the rules on opening accounts, and the rules on transferring sums to the budget. The logic behind it is straightforward. When an account is opened, the institution verifies that the payer has been registered with the tax authorities, and it reports the opening of that account to those authorities. When a tax payment order arrives instructing a transfer of funds to the budget, the institution must accept that order and execute it as a matter of priority.
A breach of these duties is not really about one client's file; it is about the institution's own procedure. That is why cases of this kind tend to surface not in a single episode but in the way a process is organised — in internal regulations, in the sequence in which operations are executed, or in the automation that sends information to the tax authorities.
It helps to read the article's list as two groups. The first concerns the account-opening stage — the requirement for the document confirming registration, and the requirement to report the opening. The second concerns an account that is already running, and deals with the order to transfer funds to the budget. In practice these two groups are served by different internal processes, so within a single institution a failure usually appears in one of them and not the other.