For example, one issue was that the company failed to submit documents to the agency for approval regarding the “impact of intensive rainfall.”

On the one hand, the state fines the company 500, 2,000, or 5,000 GEL; on the other hand, it exempts it from these fines as well as from the requirement to obtain a mineral extraction license.

The company initially arranged 8 hectares of land in the sea for the artificial peninsula before any environmental decision had been issued. According to the company, more than 41 hectares of reclaimed land have now been created.

Ambassador Batumi Island arranged the first 8 hectares of artificial land in the Black Sea without an environmental decision. Carrying out such activity without that decision is illegal, and an administrative violation report was prepared as a result.

The Environmental Supervision Department prepared the report on August 26, 2024. A few days later, the same department issued a decree terminating the administrative proceedings against Ambassador Batumi Island and giving the company only a verbal warning.

The decree states:

“LLC ‘Ambassador Batumi Island’ is recognized as having committed an offense under Article 797 (1) of the Administrative Offenses Code; however, the act shall be considered insignificant and a verbal warning shall be issued under Article 22 of the same Code.”
(Decree of September 4, 2024)

Under Article 797 (1), conducting activities subject to an environmental impact assessment without an environmental decision, or conducting screening-subject activities without a screening decision, is punishable by a fine of 7,000 to 10,000 GEL.

Nevertheless, even though the company violated this requirement and created 8 hectares of artificial land and protective structures, it received only a verbal warning.

Documents show that Ambassador Batumi Island submitted an environmental decision; however, that decision was issued on August 14, 2024 after the company had already constructed nearly 8 hectares of the peninsula.

The company explained that future activity would continue in accordance with that decision and its conditions.

Despite this explanation, Ambassador Batumi Island was fined again in March 2025 for failing to meet conditions set by the environmental decision  specifically, for failing to submit certain documents to the Environmental Agency within required deadlines.

In the department’s decree on imposing an administrative penalty, it is noted that the company’s representative appeared at the hearing and stated they had been working intensively on the documentation and requested additional reasonable time.

The company again requested a verbal warning instead of a fine.

However, since the company had already received a verbal warning earlier for violating Article 797 (1), this time they were fined 5,000 GEL under Article 798 (1). (From September 1, 2026, this fine will increase to 10,000–15,000 GEL.)

According to the March 31, 2025 decree, the Environmental Agency sent letters on March 10 and 25, stating that Ambassador Batumi Island had violated several conditions established by the environmental decision of August 14, 2024:

  • Within four months, the company had to submit calculations on the hydrology of the Kubasqali River floods, volumes of water accumulating from intensive rainfall, and sea-level scenarios; this was not done.
  • Within two months, it had to submit a geodetic monitoring plan; not done.
  • Within three months, it had to submit updated information about additional deep-soil drilling; submitted late (Feb 28, 2025, instead of Nov 14, 2024).
  • Within three months, it had to submit an updated environmental monitoring plan; submitted late (Feb 24, 2025).
  • It had to submit a plan for restoration or conservation in case activities were suspended; not done.
  • Within three months, it had to submit information on managing dredged contaminated sediments during seabed-deepening works; not done.

According to documents obtained from the Environmental Supervision Department:

  • Under a government decree of November 18, 2022, Ambassador Batumi Island was exempted for 10 months from the mineral extraction license requirement and allowed to extract 600,000 m³ of sand-gravel in Khelvachauri.
    The company failed to submit required reports on extracted material within 2 weeks after the deadline. An administrative protocol was issued on December 20, 2023.
  • The court recognized the company as an offender on November 15, 2024 but released it from liability with a verbal warning.
  • Another government decree in December 2023 again exempted the company from a license until November 30, 2024, allowing extraction of 552,500 m³ of sand-gravel.
    The company again failed to submit reports on time. Another protocol was issued on January 30, 2025.
  • On February 25, 2025 the court again recognized the company as an offender, but despite a previous warning again released it with a verbal warning.

However, Article 22 of the Administrative Code clearly states that verbal warnings cannot be reused for repeat violations of the same act.

Despite this, the company received multiple warnings for the same repeated violation.

A May 6, 2025 government decree exempted Ambassador Batumi Island from yet another mineral extraction license for 12 months in Kobuleti, permitting the extraction of 1,500,000 m³ of mineral resources.  The company paid the required 365,217 GEL fee late, on July 14, 2025.

A protocol was issued on July 15, 2025, and the case was forwarded to the Kobuleti Magistrate Court. A court ruling from September 9, 2025 fined the company 500 GEL.

In March 2025, the company was also cited for a waste-management violation under Article 32 (1) of the Waste Code.

According to the documents, on March 11, 2025, an inspection triggered by a hotline report found that the company had polluted a section of Abkhazia Street in Batumi during fence construction, leaving about 1 m³ of waste material on the roadway.

On March 27, 2025, the court fined the company 2,000 GEL.
The company appealed, arguing that the violation caused no irreversible environmental harm and should have been handled with a verbal warning.

The Appeals Court rejected the argument, stating that courts have broad discretion to determine whether a violation is “insignificant.”

While state agencies and courts debate whether Ambassador Batumi Island should pay 500, 2,000, or 5,000 GEL finesor be released from them the company has already begun constructing multi-story buildings on the artificially created land.

The company plans to build five skyscrapers on the artificial peninsula before the artificial island itself is constructed.

Ambassador Batumi Island mainly sources sand-gravel from the Chorokhi River, while the government continues exempting it from license requirements.

Experts insist that gravel must not be taken from the Chorokhi River for construction – all of it is needed for reinforcing Batumi’s coastline. The city requires at least 120,000 m³ of gravel each year to maintain its beaches, a process that already consumes millions of budget funds.

Government agencies are well aware that a new coastal protection strategy is urgently needed; otherwise, a future environmental disaster is considered unavoidable.