What Article 66² covers
Article 66² of the Georgian Code of Administrative Offences concerns one specific licence: the licence for the use, for export purposes, of fir cones and of the snowdrop bulbs and/or cyclamen tubers included in the appendices to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The article does not penalise that activity as such. It penalises the licence holder for failing to perform an obligation attached to the licence.
The structure of the article follows two separate obligations. The first is reporting: the holder must submit a report on the fulfilment of the licence conditions, in the manner and within the period established by Georgian legislation. The second is compliance with the licence conditions themselves. These are not interchangeable, and the article keeps them in separate parts. The article carries a list of amending acts: Law of Georgia No. 4651 of 5 May 2011, Law No. 4798 of 2 March 2016, Law No. 2196 of 20 April 2018, and Law No. 3668 of 15 November 2023.
Two offences and their fines
The article has two parts, and each carries its own fixed amount:
- Part 1 — failure to submit the report on fulfilment of the licence conditions in the manner and within the period established by Georgian legislation: a fine of 500 lari;
- Part 2 — breach of the licence conditions themselves: a fine of 2,000 lari.
The distinction matters. The 500-lari fine concerns a document — the report — not filed in the prescribed manner or on time. The 2,000-lari fine concerns the substance of what the licence required of you. So the first question when reading a decision is which part is relied on, because that determines what you actually have to answer, and it is not unusual for the two to be run together in correspondence when the law keeps them apart.
How the fine multiplies under the note
The article carries a note in two paragraphs, and the heaviest financial consequence sits there rather than in the parts above. The note sets out a two-step escalation:
- notwithstanding that liability has already been imposed for breach of the licence conditions, if the holder still fails to fulfil those conditions within the established period — in accordance with the procedure laid down by the Law of Georgia on Licences and Permits — the fine provided by this article is tripled;
- after that, and again notwithstanding that liability has been imposed, a repeated failure to fulfil the conditions within the period set afresh by the licence issuer results in a fine at nine times the amount provided by this article.
To take an example: where the fine for breach of the licence conditions is 2,000 lari, the tripled amount is 6,000 lari, and the ninefold amount is 18,000 lari. Both paragraphs of the note carve out one exception in the same terms — they do not apply to the cases provided for by Article 232 of the same Code. If your case is already at an escalation step, establish which period is being counted and who set it before anything else.
Who the article applies to
The text names the responsible person directly: the licence holder. What matters in these cases is therefore not who physically carried out a particular operation, but who the licence was issued to and who bore the duty to report or to comply. Where the activity was split between several people — where the collector, the carrier and the exporter were not the same person — that arrangement needs to be documented, because the article fixes the addressee of the obligation itself and does not follow the division of labour on the ground.
What to check in the case file
A case of this kind normally begins with a protocol and ends with a decision. In this category the dispute almost always turns on dates and documents, so check the following:
- which part of the article is cited — non-submission of the report, or breach of the conditions;
- whether the amount imposed matches that part — 500 or 2,000 lari, or the tripled or ninefold amount where the note has been applied;
- which specific licence condition is said to have been breached;
- what period was set, by whom, and how you were notified of it;
- what evidence exists that the report was or was not submitted.
Article 66² itself says nothing about when or where a decision may be challenged, or how such a period is counted. What it provides is the two offences, the fines of 500 and 2,000 lari, and the tripled and ninefold escalation in the note. The appeal rules come from other provisions of the Code and have to be established on your own file rather than assumed.
What a lawyer changes, and what to bring
A lawyer cannot promise you an outcome, but can control the part of the case that is within your reach: reading the classification correctly, filing in time, and putting the documents in while they can still be considered. Under this article one thing matters more than in most: stopping the escalation. The sooner it is established which condition remains unfulfilled and how much of the period is left, the smaller the chance that the case reaches the tripled or the ninefold fine.
For a consultation, bring the licence itself and its conditions; every report you have filed, together with proof of filing; your correspondence with the licence issuer, especially anything setting a period; copies of the protocol and the decision; and a record of when each document was served on you.