Remote VASP serving residents in Georgia
Foreign-incorporated entity that offers exchange, custody, or transfer services to residents of a jurisdiction without establishing a local entity or office.
Remote 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
- CDD required under Law N5183-IIs (Law of Georgia on Facilitating the Suppression of Money Laundering and Terrorism Financing) — identification and verification of customers (individuals and legal entities)
- Beneficial ownership identification required (25%+ ownership threshold for legal entities)
- Ongoing transaction monitoring and business relationship monitoring
- Enhanced Due Diligence (EDD) for PEPs, high-risk jurisdictions, complex/unusual transactions
- Suspicious Transaction Reporting (STRs) to the LEPL Financial Monitoring Service of Georgia (FMS)
- Record-keeping: minimum 5 years post-relationship/transaction for CDD, transaction, correspondence, and risk-assessment records
- Appointment of an AML/CFT officer
- Business-wide and customer-level risk assessment frameworks required
- No tipping-off prohibition on STR filings
Key Restrictions
- Must be a legal entity registered in Georgia — a foreign-incorporated entity cannot serve residents remotely without establishing a local entity
- Must maintain a registered office in Georgia (significant local presence required)
- Minimum share capital of 1,000,000 GEL required for VASP authorization
- Must obtain VASP Authorization from the National Bank of Georgia (NBG) — covers exchange (fiat/crypto and crypto/crypto), transfer, and custody services
- Must maintain sufficient operational capital beyond the minimum share capital requirement
- Surety bond requirements also apply under the money transmitter licensing track if transmission of monetary value is involved
Key Risks
- Operation without a Georgia-registered entity and NBG VASP authorization would be illegal — NBG has sole licensing and supervisory authority; unlicensed cross-border servicing carries significant enforcement risk
- The NBG resolution N111/04 and AML amendments explicitly bring VASPs under Georgia's regulatory perimeter, leaving no unregulated gap for foreign remote operators
- AML/CFT obligations (STRs to FMS, CDD, record-keeping) are compulsory for licensed VASPs; a remote operator without local presence cannot practically comply with these obligations
- Confusion risk: some fact IDs reference 'Georgia Department of Banking and Finance (GDBF)' and US state-level law (Georgia, USA), not Georgia the country — must ensure correct jurisdiction is applied
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.
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).
Required License: VASP Authorization from the NBG.
Legal Entity: The applicant must be a legal entity registered in Georgia.
Minimum Capital Requirements:
Applicants must meet minimum share capital requirements. The specific amounts are typically defined in NBG resolutions.
As of recent implementations, the required share capital for a VASP is 1,000,000 GEL (Georgian Lari).
A significant local presence is required, including:
A registered office in Georgia.
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.
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:
Continuously monitoring the business relationship and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile, including the source of funds or wealth.
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.
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.
Identification of Suspicion: VASPs must establish systems and controls to identify transactions or activities that are unusual or give rise to a suspicion of money laundering or terrorism financing.
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a foreign-incorporated remote VASP cannot serve Georgian residents without first establishing a Georgian-registered legal entity, obtaining NBG VASP authorization (minimum 1,000,000 GEL capital, local office, comprehensive AML/CFT program), and complying with full AML obligations supervised by the NBG and FMS; unlicensed cross-border servicing is not permitted and carries enforcement risk.
Questions this verdict aims to answer
- May a non-resident provider serve residents from abroad?
- Does cross-border service trigger licensing, registration, or AML obligations?
- What enforcement risk exists for unlicensed remote operators?