On-shore VASP in Georgia
Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.
On-shore VASP is conditionally permitted in Georgia with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- VASP Authorization from the NBG required.
- Must implement robust AML/KYC policies under the Law of Georgia on Facilitating the Suppression of Money Laundering and the Financing of Terrorism (Law N5183-IIs).
- Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures required.
- Suspicious Transaction Reports (STRs) must be filed with the LEPL Financial Monitoring Service of Georgia (FMS).
- Business-wide and customer-specific risk assessment frameworks required.
- Appointment of an AML/CFT officer required.
- Records must be kept for at least five years following termination of business relationship or date of occasional transaction.
- No-tipping-off obligations apply.
Key Restrictions
- Applicant must be a legal entity registered in Georgia.
- A registered office in Georgia is required — significant local presence is mandatory.
- Minimum share capital requirement: 1,000,000 GEL.
- Must maintain sufficient operational capital to cover operational risks and costs.
- Activities must fall within licensed VASP categories (exchange fiat/crypto, exchange crypto/crypto, transfer, custody, participation in ICO-related financial services).
Key Risks
- Regulatory framework is relatively new (2023 NBG Resolution) — interpretation and enforcement patterns are still evolving.
- High minimum capital (1,000,000 GEL) creates a significant entry barrier.
- Dual regulatory touchpoints: NBG for VASP licensing and AML, plus FMS for suspicious transaction reporting.
- No explicit crypto-specific asset segregation rules for custody — reliance on implicit MTL-style standards creates ambiguity.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
National Bank of Georgia (NBG): The central bank is the sole licensing and supervisory authority for VASPs in Georgia.
Required License: VASP Authorization from the NBG.
Legal Entity: The applicant must be a legal entity registered in Georgia.
Minimum Capital Requirements:
As of recent implementations, the required share capital for a VASP is 1,000,000 GEL (Georgian Lari).
In addition, VASPs must maintain sufficient operational capital to cover their operational risks and costs.
Applicants must establish and implement robust Anti-Money Laundering (AML) and Know Your Customer (KYC) policies and procedures in compliance with the Law of Georgia on Facilitating the Suppression of Money Laundering and the Financing of Terrorism and relevant NBG regulations.
Customer due diligence (CDD) and enhanced due diligence (EDD) procedures.
Reporting of suspicious transactions (STRs) to the Financial Monitoring Service of Georgia (FMS).
Risk assessment frameworks (business-wide and customer-specific).
Appointment of an AML/CFT officer.
A significant local presence is required, including:
A registered office in Georgia.
Exchange between virtual assets and fiat currencies.
Exchange between one or more forms of virtual assets.
Transfer of virtual assets.
Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets (custody services).
Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset.
Law of Georgia on Facilitating the Suppression of Money Laundering and Terrorism Financing (Law N5183-IIs, adopted December 29, 2006, as amended): This is the fundamental AML/CFT law in Georgia. It was significantly amended in 2023 to explicitly include Virtual Asset Service Providers (VASPs) as "obliged entities" (or "reporting entities"), bringing them under the scope of AML/CFT regulations.
National Bank of Georgia (NBG) Resolution N111/04 of July 13, 2023, "On Approving the Rules for Regulation of Activities of Virtual Asset Service Providers": This crucial resolution by the NBG provides detailed rules and guidelines for the licensing, supervision, and AML/CFT compliance of VASPs. It elaborates on the requirements stipulated in the main AML law.
Identification and Verification of the Customer:
Purpose and Intended Nature of the Business Relationship:
Reporting Obligation: If a VASP knows, suspects, or has reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to terrorism financing, it must promptly report this to the LEPL Financial Monitoring Service of Georgia.
No Tipping-Off: VASPs and their employees are prohibited from disclosing to the customer or any third party that a STR has been, or will be, submitted.
Duration: Records must be kept for a period of at least five years following the termination of a business relationship or the date of an occasional transaction.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — locally-incorporated on-shore VASPs are permitted in Georgia subject to obtaining a VASP Authorization from the National Bank of Georgia, which requires a legal entity registered in Georgia, minimum share capital of 1,000,000 GEL, robust AML/CFT programs, and substantial local presence.
Questions this verdict aims to answer
- What license(s) are required to operate locally?
- What capital, governance, and reporting obligations apply?
- What is the application process and timeline?