---
title: "Compliance Monitoring"
url: "https://legal.ge/en/service/corporate-and-commercial-law-en/compliance-monitoring-en"
field: "Corporate & Commercial Law"
description: "Compliance monitoring under Georgian AML law: arts 12, 8, 38 and 43-1 — internal control, inspection and a 1 000 lari fine. Legal.ge."
reviewed: "2026-06-27"
updated: "2026-11-08"
publisher: "legal.ge"
---

# Compliance Monitoring

> Source: legal.ge, https://legal.ge/en/service/corporate-and-commercial-law-en/compliance-monitoring-en

## Compliance Monitoring: the Regime of Operational Oversight

Designing a compliance program is a matter of design; monitoring is about how that design works in daily practice and how the state verifies it. The law on the prevention of money laundering and terrorism financing creates two layers here: internal ongoing monitoring and external inspection, with the consequences of non-compliance set out separately.

This page is precisely about operational control: how preventive measures are carried out during the life of a relationship, how risks are reassessed, and who checks the system from outside.

## Internal Ongoing Monitoring

Under Article 12, the accountable person applies preventive measures according to the client’s risk level before a one-off transaction and before establishing a business relationship, and also with appropriate periodicity — during the relationship and upon material changes in the client’s circumstances. Monitoring is thus not a one-off check: it spans the entire life of the relationship.

Verification has a degree of flexibility: at lower risk, verification of the client or beneficial owner may be completed after the relationship is established, where this is necessary to avoid interrupting service — but it must then be completed as quickly as possible within reasonable limits. Opening or maintaining an anonymous or fictitiously named account is categorically prohibited; electronic identification follows the procedure established by the supervisory authority and agreed technical procedures.

The technical side of identification is regulated in detail as well: a financial institution is empowered to open an account before verification, where the execution of operations on the account in the client's name or by the client's order is prohibited until the verification is completed; preventive measures may be carried out electronically, without direct contact with the client; and the list of identification data is determined by a subordinate act of the head of the service.

Article 8 gives monitoring its substantive core: the accountable person periodically assesses and records the risks connected with its activity — for a head enterprise, also at group level; the client’s risk level is determined before a one-off transaction and before establishing the relationship, and then periodically and upon material changes. Before introducing a new technology, product or service, the associated risks are assessed in advance.

Article 8 also enumerates the grounds of risk assessment: the client and the beneficial owner, the essence of their activity and the jurisdiction of their location, the product, the service or its delivery channel, the transaction and other risk factors. To manage and reduce the identified risks the accountable person carries out effective measures, and in the assessment it considers the national risk-assessment report and the action plan, the guidance and recommendations of the service and the supervisory authority — the results of the national report are also reflected in the system.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/corporate-and-commercial-law-en/compliance-monitoring-en

### When and how often are inspections?

Remote or on-site; type and frequency are set by the risk level.

### Can verification be completed later?

Yes, at lower risk, to avoid interrupting service — but as quickly as possible.

### Are anonymous accounts allowed?

No, prohibited.

### What fine applies?

A warning first; repetition — a 1 000 lari fine; accountable persons are excluded.