Suspicious Activity Reporting (SAR) is one of the most sensitive areas of legal responsibility for the financial sector in Georgia. It involves a process where an obliged entity informs the Financial Monitoring Service of Georgia about any transaction or its attempt if there is a reasonable ground for suspicion that the assets were obtained through criminal means. Georgia, actively striving for European standards, continuously refines its AML (Anti-Money Laundering) regulations. This means that businesses need not only internal control but also qualified legal support to correctly assess when a report is mandatory and when it might cause an unjustified violation of client rights. The Legal.ge platform provides access to experts specializing in financial crime prevention.
What does the Suspicious Activity Reporting service cover?
Professional services related to suspicious activity reporting ensure a business's full compliance with regulatory requirements. The service includes: auditing and setting up the internal system for detecting suspicious operations; legal analysis of specific "cases" to determine the validity of the suspicion; filling out and sending reporting forms (SAR/STR) through the Financial Monitoring Service (FMS) portal; maintaining confidentiality policy when dealing with clients; and representation before the regulatory body in case of follow-up requests. Specialists will also help implement a "Risk-Based Approach," reducing the burden of excessive reporting and increasing the probability of identifying actually suspicious cases.
Common real-world scenarios
In everyday business activities, sending a suspicious report may become necessary in diverse situations. For example, when a client refuses to provide additional information about the source of funds or the submitted documents look suspicious. A second scenario involves transactions that clearly lack economic or commercial logic. It is also common for a client to try to speed up an operation without any basis and be ready to pay an disproportionately high commission. Another important scenario involves indirect links of persons on sanctioned lists with the transaction. Legal assistance in such times is necessary to correctly assess the facts and avoid business liability for violating the law.
Georgian Legal Framework
The main legal act in this field is the Law of Georgia on Facilitating the Prevention of Money Laundering and Terrorism Financing. This law establishes the list of obliged entities, which includes not only banks but also real estate agents, precious metal dealers, and other subjects. Regulations of the Financial Monitoring Service of Georgia, defining the format and rules for reports, are also in effect. For the banking sector, Instructions of the National Bank of Georgia detailing the monitoring process are decisive. The legislation provides for serious sanctions for failure to fulfill the reporting obligation, which may include large fines as well as the suspension of business licenses.
Step-by-step process when working with a specialist
The process begins with a detailed study of the current incident. In the first stage, the lawyer checks if the operation falls under the "indicators" defined by law. In the second stage, a revision of all existing data about the client (EDD - Enhanced Due Diligence) takes place. In the third stage, a conclusion on the validity of the suspicion is written. If the suspicion is confirmed, in the fourth stage, the suspicious activity report form is filled out and sent to the appropriate body. The fifth stage involves determining a strategy for continuing or terminating the relationship with the client without violating the "Tipping Off" prohibition. A specialist ensures that this entire chain is documented and protected for audit purposes.
Why choose Legal.ge?
Reporting suspicious activities requires not only knowledge of the law but also practical experience in dealing with the regulator. On the Legal.ge platform, you will find top Compliance specialists with extensive experience in the legal support of the financial sector. Our experts will help you manage risks correctly, protecting you from state sanctions as well as reputational damage. Find a specialist on Legal.ge and be confident that your business fully complies with Georgian and international standards. Our platform ensures reliability and professionalism at all stages of your activity.
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