Who is an accountable person in the private banking sector?

The commercial bank and other financial institutions listed by the law; also advocates, notaries, accountants and auditors when performing the services named in the law.

How is the beneficial owner determined?

The natural person who is the ultimate owner or controller of the client or on whose behalf the transaction is concluded; for a legal person — whoever directly or indirectly owns twenty-five percent or more of the shares.

What does the law require from a bank in relation to a politically active client?

Senior management approval for establishing or continuing the relationship, reasonable measures to establish the origin of assets, and enhanced monitoring; the regime also covers family members and close associates.

Why is a risk assessment system necessary?

The law obliges the accountable person to introduce an effective system, to assess risks periodically and to justify the completeness of the assessment to the supervisory authority on request.

Private Banking Compliance in Georgia

Private Banking Compliance Under Anti-Money-Laundering Legislation

Private banking — individual service for high-value clients and the management of substantial funds — stands at the centre of the legislation on the prevention of money laundering and the financing of terrorism. A commercial bank is an accountable person under this law: a full-fledged risk assessment and management system is required, together with the identification of the client and the beneficial owner and, at elevated risk, enhanced measures.