← Regulations / Georgia / Operating Models / Self-custodial wallet

Self-custodial wallet / non-custodial software in Georgia

Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.

Conditional AI-Generated · Unreviewed

Self-custodial wallet is conditionally permitted in Georgia without local incorporation, subject to AML obligations and none licensing burden.

Verdict Details

Permitted
conditional
Local entity required
No
Licensing burden
None
Last updated
2026-07-13

AML Obligations

  • No AML obligations attach — the publisher of non-custodial/self-custodial software never holds, controls, or has access to user funds, so it does not meet the VASP definition thresholds under Georgian law.
  • Georgian VASP licensing applies only to safekeeping/administration of virtual assets or instruments enabling control over virtual assets (custody services) — see ge.licensing.safekeeping-andor-administration-of-virtual — which does not cover mere software publishing.

Key Restrictions

  • Must not provide any custody, transfer, exchange, or order-routing services on behalf of users — any feature that touches user funds or private keys on the user's behalf could trigger VASP classification.
  • Any in-app fiat on-ramp, swap aggregator, or staking service integrated into the wallet may create a VASP nexus for the publisher, depending on how it is structured and who executes the transaction.

Key Risks

  • Regulatory boundary risk: If the NBG or FMS interprets the software's private-key management features (e.g., recovery seed generation, cloud backup, key-share services) as 'instruments enabling control over virtual assets,' the publisher could be reclassified as a VASP retroactively.
  • Consumer-protection exposure: Georgian law may impose product-liability or software-safety obligations on publishers, though no crypto-specific consumer-protection rules are evident in the provided facts.
  • Enforcement precedent risk: Other jurisdictions (e.g., FinCEN in the US) have pursued wallet providers on gateway-integration theories; Georgian regulators may similarly look at the totality of services bundled with the wallet.

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 60% confidence

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets (custody services).

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
licensing 60% confidence

Required License: VASP Authorization from the NBG.

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
licensing 60% confidence

Custody Providers (Virtual Asset Custody Providers):

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
licensing 60% confidence

Exchange between virtual assets and fiat currencies.

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
licensing 60% confidence

Transfer of virtual assets.

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
licensing 60% confidence

Legal Entity: The applicant must be a legal entity registered in Georgia.

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
licensing 60% confidence

Minimum Capital Requirements:

[primary] matsne.gov.ge [primary] matsne.gov.ge [primary] matsne.gov.ge
aml 60% confidence

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.

[primary] nbg.gov.ge [secondary] fms.ge
aml 60% confidence

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.

[primary] nbg.gov.ge [secondary] fms.ge
custody 40% confidence

No specific "custodial license" for digital assets.

[primary] dbf.georgia.gov — Advisory Regarding Activities Involving Virtual Currency 12 2021

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 — a publisher of non-custodial/self-custodial wallet software that never holds, controls, or accesses user funds does not qualify as a VASP under Georgian law and therefore faces no licensing or AML obligations, but any bundling of custody-adjacent services (key recovery, integrated exchange, staking) could trigger VASP classification.

Questions this verdict aims to answer

  • Does software publishing trigger VASP / MSB classification?
  • Do AML obligations attach when no custody exists?
  • What disclosure or consumer-protection rules apply?