Stablecoin issuer / redeemer in Georgia
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer 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
- Customer Due Diligence (CDD) — must identify and verify all customers (individuals: full name, DOB, address, nationality, ID document; legal entities: name, legal form, registration, authorized persons) — per LoVA and NBG Resolution N111/04.
- Beneficial Ownership identification — must identify natural persons who ultimately own or control the customer (25%+ shareholding threshold) — per ge.aml.identification-of-beneficial-owners.
- Enhanced Due Diligence (EDD) for PEPs, high-risk jurisdictions, and complex/unusual transactions — per ge.aml.enhanced-due-diligence-edd.
- Continuous transaction monitoring — must monitor business relationships and transactions to ensure consistency with customer risk profile — per ge.aml.continuously-monitoring-the-business-relationship.
- Suspicious Transaction Reporting (STR) — must report to the LEPL Financial Monitoring Service of Georgia when there is knowledge or suspicion of ML/TF — per ge.aml.reporting-obligation-if-a-vasp.
- Record-keeping — all CDD, transaction, and correspondence records must be kept for at least 5 years after termination of business relationship — per ge.aml.duration-records-must-be-kept.
- Appointment of an AML/CFT officer — per ge.licensing.appointment-of-an-amlcft-officer.
- Prohibition on tipping-off — VASPs and employees must not disclose STR filings to customers or third parties — per ge.aml.no-tipping-off-vasps-and-their.
Key Restrictions
- Must be a legal entity registered in Georgia — per ge.licensing.legal-entity-the-applicant-must.
- Must obtain a VASP license from the National Bank of Georgia (NBG) — per ge.stablecoin.licensing-scope-any-entity-wishing.
- Minimum share capital of 1,000,000 GEL required for VASP license — per ge.licensing.as-of-recent-implementations-the.
- EMTs must be fully backed by fiat currency held in separate accounts at credit institutions, segregated from issuer operating funds — per ge.stablecoin.must-be-fully-backed-by and ge.stablecoin.the-funds-must-be-held.
- ARTs must be backed by a sufficient, diversified, segregated reserve of assets held by independent custodians — per ge.stablecoin.must-be-backed-by-a and ge.stablecoin.the-assets-must-be-held.
- Reserve investments limited to secure, low-risk assets — per ge.stablecoin.investment-of-reserve-funds-must.
- Issuers must have clear and detailed policies for the stabilization mechanism — per ge.stablecoin.issuers-must-have-clear-and.
- Must submit a whitepaper for the stablecoin as part of licensing — per ge.stablecoin.clear-business-plans-and-whitepapers.
- Must demonstrate robust governance, operational resilience, IT security, and risk management systems — per ge.stablecoin.robust-governance-arrangements through ge.stablecoin.effective-risk-management-systems-including.
Key Risks
- Secondary legislation and detailed capital/reserve requirements are still being developed by NBG — regulatory details may shift during implementation.
- No official English translation of the final enacted LoVA is publicly available from Georgian government sources, creating interpretation risk for foreign operators.
- Algorithmic or unbacked stablecoins may be treated as generic virtual assets with no clear licensing path — per ge.stablecoin.other-virtual-assets-if-a.
- Enforcement precedent under the new LoVA regime is limited given the law's recent adoption.
- Reserve segregation and custody rules for virtual assets are still being operationalized — unclear how NBG supervises on-chain reserve attestation.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Law of Georgia on Virtual Assets (LoVA), Article 3: Defines "Virtual Asset," "Virtual Asset Service Provider," and references the classification consistent with MiCA.
Licensing Scope: Any entity wishing to issue ARTs or EMTs in Georgia must obtain a license from the NBG. This also applies to entities providing services related to these tokens (e.g., exchange, custody).
E-money Tokens (EMTs):
Must be fully backed by fiat currency (e.g., Georgian Lari, USD, EUR) held in separate accounts in credit institutions.
The funds must be held in a way that is separate from the issuer's operating funds, ensuring segregation in case of issuer insolvency.
Investment of reserve funds must be in secure, low-risk assets.
Asset-Referenced Tokens (ARTs):
Must be backed by a sufficient, diversified, and segregated reserve of assets.
The composition of the reserve assets must be resilient to market shocks and allow for redemption.
The assets must be held by custodians who are independent from the issuer and subject to strict regulatory oversight.
Issuers must have clear and detailed policies for the stabilization mechanism.
Requirements: Licensing involves demonstrating:
Robust governance arrangements.
Adequate capital requirements (to be set by NBG).
Operational resilience and IT security.
Fit and proper criteria for management and shareholders.
Effective risk management systems, including AML/CFT compliance.
Clear business plans and whitepapers for the stablecoins.
National Bank of Georgia (NBG): The central bank is the sole licensing and supervisory authority for VASPs in Georgia.
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).
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.
Appointment of an AML/CFT officer.
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:
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.
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.
Law of Georgia on Virtual Assets (LoVA), Article 3: Defines "Virtual Asset," "Virtual Asset Service Provider," and references the classification consistent with MiCA.
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 stablecoin issuer may operate in Georgia as a VASP-licensed entity (NBG) with 1,000,000 GEL minimum capital, full fiat/reserve backing segregated from issuer funds, robust AML/CFT obligations, and local incorporation, but secondary legislation and English translations of the final law remain incomplete, introducing some implementation ambiguity.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?