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New policy by tbc bank

Starting April 1, 2024, TBC Bank is implementing updated policies and procedures to comply with international sanctions.
April 1, 2024
Marina Piduashvili, Partner, Lawyer
Recently, the leading Georgian bank, TBC Bank, introduced updated policies and procedures, designed to comply with international sanctions imposed by the UN, UK, USA, and EU.

Who does this affect?

The policy applies to both commercial and non-commercial organizations, as well as individuals, who send or receive funds to countries of "special attention."

Let’s delve into the details.

Restrictions on currency transactions with the russian federation

Checks on currency transactions involving the Russian Federation are being tightened. The bank may request additional documents such as invoices, contracts, certificates of origin of goods, etc., to verify whether your transaction falls under sanctions.

Transactions involving designated/sanctioned individuals or entities supporting Russia’s military-industrial complex are strictly prohibited.

Restrictions on currency transactions with other countries

Indirect transactions with sub-sanctioned countries, such as the Islamic Republic of Iran, are also prohibited.

Specifically, the prohibition extends to international trade settlements where the counterparty, country of origin of goods, transport route, or country of registration of the transport vehicle (in aviation, maritime, land, and rail transport) is connected to Iran or any other sanctioned country.

Terms for sending international payments

Documentation requirements for sending international payments depend on the recipient company’s country.
For more detailed document requirements, you can visit the TBC Bank website

Terms for receiving international payments

For payments received from abroad, TBC Bank may request additional documents confirming the origin of the transfer and may suspend the transfer until they are provided.

Special attention is paid to payments from countries such as Azerbaijan, Armenia, Russian Federation, Kazakhstan, Kyrgyzstan, Belarus, and UAE.

If the bank detects a transaction linked to sanctions, it reserves the right to:

  • Suspend the transaction until all required documents are received
  • Request documents for past transactions
  • Cancel the transaction if the client fails to provide the required documentation and/or if the transaction does not comply with the bank’s internal policy
  • Close the client’s accounts (without prior notice)
Stay tuned for messages from the bank to avoid missing requests for additional documents. And if you need assistance with document management or representation of your interests, feel free to contact the specialists at Just Advisors.

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