On April 4, 2018, the Public Defender of Georgia addressed the National Bank of Georgia with a general proposal to develop simple foreseeable regulations to ensure that foreign citizens can enjoy banking services in commercial banks without discrimination on any grounds.

The Public Defender has been applied by citizens in Nigeria, Iran and Syria, who complained about encountering obstacles in the commercial banks of Georgia. In particular, they said they had been asked to provide recommendations from the banks registered in the US, Canada, Australia or any EU member states, when they wanted to get a student card and or a bank statement, or to open an account. The applicants could not provide such kind of documents for objective reasons.

The respondent banks named the requirements of the Law of Georgia on Facilitating the Prevention of Illicit Income Legalization as a legitimate objective of such treatment of the applicants. In this connection, the Public Defender indicated that commercial banks were to define expected risks from a particular person on the basis of individual assessment, as a result of directly inspecting the person, and that their approach should not be blanket or conditioned by the nationality of any country.

In the general proposal, the Public Defender of Georgia also indicated that financial services and prevention of money laundering and financing of terrorism are quite specific issues, assessment of which, in some cases, goes beyond the competence of the Public Defender. Consequently, flexible regulations should be developed by the state supervisory and financial institutions in line with the recommendations of a financial action task force and financial inclusion of the population should be facilitated.