Cryptocurrency is legal and regulated in Georgia. The jurisdiction has a comprehensive, dedicated crypto framework with licensing and active enforcement. Ministry of Finance is the responsible authority. Primary legislation: AML/CFT Law. The FATF Travel Rule has not been adopted. Tax treatment: National Bank of Georgia (NBG) – Regulates VASPs and enforces AML/CFT standards..
Derived from 537 sourced facts for Georgia · last updated · primary sources
Georgia regulates crypto through a dedicated framework anchored in the Law of Georgia on Virtual Assets (June 2023), with the National Bank of Georgia (NBG) as the sole licensing and supervisory authority; licensing is required for fiat-to-crypto exchange, crypto-to-crypto exchange, custody, and participation in virtual asset issuance or sale. The NBG operationalizes this regime through Resolution N111/04 (July 2023) and Ordinance N59/04 (April 2024), mandating AML/KYC obligations under the amended Law N5183-IIs, including full customer identification and verification for both individuals and legal entities, plus structured reporting requirements. The LoVA explicitly aligns its virtual asset classifications—including Asset-Referenced Tokens and E-money Tokens—with MiCA definitions, making Georgia's framework notably interoperable in concept with EU standards, though it operates as an independent regime outside MiCA's scope. (nbg.gov.ge, matsne.gov.ge, dbf.georgia.gov)
National Bank of Georgia Resolution No. 126/04 of December 29, 2022, "On Approval of the Rules for Regulation of Virtual Asset Service Providers" (NBG VASP Rules): This is the core regulatory document that details the licensing,…
Ministry of Finance: Primarily responsible for tax policy regarding virtual assets.
Can specific business models operate in Georgia? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
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AI · Unreviewed| Law / Regulation | Year | Scope |
|---|---|---|
| AML/CFT Law | Law of Georgia on Facilitating the Suppression of Money Laundering and the Financing of Terrorism (AML/CFT Law): | |
| VASP Law | Law of Georgia on Virtual Asset Service Providers (VASP Law) | |
| NBG Statement on Adoption of VASP Law (July 2023) | 2023 | NBG Statement on Adoption of VASP Law (July 2023) |
| ORGANIC LAW OF GEORGIA ON THE NATIONAL BANK OF GEORGIA | ORGANIC LAW OF GEORGIA ON THE NATIONAL BANK OF GEORGIA |
Exchange between virtual assets and fiat currencies.
Exchange between one or more forms 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.
Required License: VASP Authorization from the NBG.
This falls directly under points 1 and 2 of the VASP definition.
This falls directly under point 4 of the VASP definition.
If a payment processor only handles fiat currency payments for the purchase of virtual assets (e.g., a traditional payment gateway facilitating fiat payments to an exchange), it might primarily fall under general payment service regulations, but the connection to virtual assets will still bring it under the NBG's scrutiny regarding AML/CFT for VASPs. However, if they directly facilitate VA transfers or exchanges as part of their payment service, a VASP license is required.
Legal Entity: The applicant must be a legal entity registered in Georgia.
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).
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 registered office in Georgia.
Local management (e.g., general director, compliance officer) that is "fit and proper" and resident in Georgia.
Fit and Proper Requirements: All management board members, supervisory board members, and significant shareholders must meet "fit and proper" criteria, including having relevant experience, no criminal record, and demonstrating good repute.
Organizational Structure: A clear and effective governance structure, internal control mechanisms, risk management systems, and audit functions must be in place.
Robust and secure IT systems, data protection measures, cybersecurity protocols, and business continuity plans (BCP) and disaster recovery plans (DRP) must be established to protect client assets and data.
Independent security audits may be required.
Business Plan: A detailed business plan outlining the intended services, target market, operational model, technological infrastructure, and financial projections.
Internal Rules and Policies: Comprehensive internal rules and procedures covering all operational aspects, including client onboarding, transaction execution, asset safeguarding, complaints handling, and compliance.
Professional Indemnity Insurance: The NBG may require specific insurance coverage.
Pre-Application Consultation (Recommended): Applicants may engage with the NBG to discuss their proposed business model and clarify regulatory requirements. While not always mandatory, it can streamline the process.
Preparation of Application Documents: This is the most extensive phase, involving the compilation of:
Financial projections (usually for 3-5 years).
AML/CFT policies and procedures manual.
Resumes and "fit and proper" declarations for key personnel and significant shareholders.
Evidence of IT and cybersecurity infrastructure.
Internal rules, risk management policies, and operational manuals.
Legal documents of the Georgian entity (charter, registration certificates).
Any other documentation as required by NBG resolutions.
Submission of Application: The complete application package is submitted to the NBG. An application fee is typically required.
The NBG reviews the application for completeness and compliance with all requirements.
They may request additional information, clarifications, or amendments to the submitted documents.
Interviews with key personnel may be conducted.
On-site inspections of proposed operational facilities may occur.
If satisfied, the NBG issues the VASP authorization.
If the application is rejected, the NBG provides reasons for the refusal.
Post-Authorization Obligations: Once authorized, VASPs are subject to ongoing supervisory obligations, including regular reporting to the NBG and the FMS, compliance with all relevant regulations, and potential on-site inspections.
This is the foundational law. It sets out the definition of VASPs, the requirement for authorization, NBG's supervisory powers, and general principles.
Official Source (Georgian Parliament): https://matsne.gov.ge/ka/document/view/5895028?publication=0
Note: An official English translation may be available via subscription legal databases or through the NBG website's English section once fully implemented and stable.
National Bank of Georgia Resolution N133/04 on Approving the Rules for Licensing and Supervision of Virtual Asset Service Providers (November 29, 2023):
This resolution provides the detailed rules for how the Law on Virtual Assets is implemented, including specific requirements for licensing, minimum capital, fit and proper tests, operational standards, reporting, and supervision.
Official Source (NBG, likely on their resolutions page or Matsne): https://matsne.gov.ge/ka/document/view/6064360?publication=0
Note: This resolution is critical for understanding the practical requirements.
This law governs the general AML/CFT obligations for all obligated entities in Georgia, including VASPs.
Note: Specific NBG regulations for VASPs will build upon this general law.
The NBG's official website is the primary source for updated information, press releases, and publications related to financial regulation. Look for sections on "Financial Sector Supervision" or "Virtual Assets."
National Bank of Georgia (NBG): This is the primary regulator responsible for the licensing, supervision, and regulation of Virtual Asset Service Providers (VASPs). The NBG issues secondary legislation (rules, decrees) to implement the VASP law.
Official Website: National Bank of Georgia
Financial Monitoring Service of Georgia (FMS): While the NBG licenses and supervises, the FMS is the financial intelligence unit responsible for receiving, analyzing, and disseminating suspicious transaction reports related to money laundering and terrorist financing, including those from VASPs.
Official Website: Financial Monitoring Service of Georgia
Ministry of Finance: Primarily responsible for tax policy regarding virtual assets.
Law of Georgia on Virtual Asset Service Providers (VASP Law)
Defines "virtual asset" and "virtual asset service provider" (VASP).
Mandates licensing and registration for all entities operating as VASPs (e.g., virtual asset exchanges, custodians, brokers).
Establishes comprehensive AML/CFT obligations for VASPs, including customer due diligence (CDD), record-keeping, suspicious transaction reporting (STR), and sanctions screening.
Grants the National Bank of Georgia the authority to issue licenses, conduct supervision, set capital requirements, and enforce compliance.
Includes provisions for consumer protection and market integrity.
Reference (While an official English translation of the enacted law might not be readily available on a single NBG page, its passage and content are widely reported by NBG and legal firms):
NBG Statement on Adoption of VASP Law (July 2023)
PwC Summary on Georgia's VASP Law (March 2024) (Provides a good overview of the law's content and effective date)
Law of Georgia on Facilitating the Prevention of Illicit Income Legalization (Money Laundering) and Terrorism Financing (AML/CFT Law)
Date: Most recent major revision in 2019 (No. 4930-IIს)
Key Provisions: This overarching law establishes the general AML/CFT framework in Georgia, to which VASPs are now explicitly subject under the VASP Law. It defines reporting entities, obligations for customer identification, record-keeping, and reporting of suspicious activities to the FMS.
Reference (Official source for Georgian legislation - may require translation): The Legislative Herald of Georgia (Mtsignobartukhutsesi)
Licensing is Mandatory: As of March 1, 2024, entities operating as Virtual Asset Service Providers (VASPs) in Georgia are required to obtain a license from the National Bank of Georgia (NBG). This includes:
Exchanges facilitating the trade of virtual assets for fiat currency or other virtual assets.
Platforms offering virtual asset transfers.
Providers of other financial services related to virtual assets.
Supervision and Compliance: Licensed VASPs are subject to ongoing supervision by the NBG and must comply with stringent AML/CFT requirements, capital adequacy rules, and other prudential standards.
Penalties for Non-Compliance: Operating as a VASP without a license can lead to significant penalties, including fines and potential criminal charges.
Individual Trading: The VASP Law primarily targets service providers. Individual participation in virtual asset trading for personal use is not banned, but individuals engaging with unlicensed VASPs do so at their own risk. All transactions with licensed VASPs, however, will be subject to the VASP's AML/CFT procedures.
Taxation: The Ministry of Finance generally treats virtual assets as property for tax purposes, and capital gains from their sale are typically subject to income tax.
Official Source (Georgian Parliament): https://matsne.gov.ge/ka/document/view/154749?publication=8
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) Ordinance N59/04 of April 2, 2024, "On the Approval of Rules for Reporting and Publication of Information by Virtual Asset Service Providers": This ordinance further specifies reporting and publication requirements, including those relevant for AML/CFT oversight.
For Individuals: Obtaining and verifying details such as full name, date and place of birth, address, nationality, and identification document details (e.g., passport or ID card number, issuing authority, expiry date). Verification typically involves reliable, independent source documents or data.
For Legal Entities: Obtaining and verifying the legal entity's name, legal form, registration number, registered address, and the names of individuals authorized to act on behalf of the entity. Verification involves official corporate documents.
Identifying the natural person(s) who ultimately own or control the customer, and verifying their identity. This applies to both individual and legal entity customers. For legal entities, this typically means identifying individuals holding 25% or more of the shares or voting rights, or otherwise exercising control.
Understanding the purpose and nature of the customer's activities and the intended business relationship with the VASP. This helps assess the risk profile.
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.
Applying EDD measures for higher-risk situations, such as relationships with Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, or complex and unusual transactions. EDD may involve obtaining additional information on the source of funds/wealth, purpose of transactions, and senior management approval for the relationship.
VASPs may apply SDD in specified lower-risk scenarios, as permitted by the NBG.
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 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.
Content of Report: The report must include all available information concerning the customer, the transaction(s), and the grounds for suspicion.
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.
CDD Information: All documents and data obtained during the CDD process (identification documents, beneficial ownership information, risk assessments).
Transaction Records: Details of all transactions, including amounts, types of virtual assets, currencies involved, dates, times, and parties to the transaction. This should allow for the reconstruction of individual transactions.
Correspondence: Records of internal and external communication related to AML/CFT, including any STRs filed and the analysis supporting the decision to file or not file a report.
Risk Assessments: Documentation of institutional and customer-specific risk assessments.
The NBG is the main supervisory authority for VASPs in Georgia. It is responsible for licensing, regulating, and overseeing the compliance of VASPs with the AML/CFT framework, including CDD and record-keeping requirements, as well as general prudential regulation.
The FMS is Georgia's Financial Intelligence Unit (FIU). It is the central authority for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial intelligence to law enforcement agencies. VASPs report their STRs directly to the FMS.
Virtual Asset Service Providers (VASPs) are recognized as regulated obliged entities under Georgia's AML/CFT framework, with the National Bank of Georgia (NBG) designated as the supervisory authority for VASP compliance with anti-money laundering obligations AML / CFT Supervision.
The primary legal basis for VASP regulation is the Law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism," which grants NBG authority to supervise virtual asset service providers AML / CFT Supervision.
Georgia's regulatory framework for virtual assets is still developing, with no comprehensive standalone crypto-asset law currently in force; instead, VASPs fall under the broader financial regulatory and AML/CFT supervision regime administered by NBG Regulatory Framework.
The NBG has published its AML/CFT supervision framework listing VASPs among obliged entities, indicating that registration or authorization through the central bank's AML/CFT supervisory process is required for crypto businesses operating in Georgia AML / CFT Supervision.
The practical reality is that while VASPs are formally recognized as supervised entities, the specific travel-rule implementation details—including threshold amounts and technical standards for crypto transfers—must be derived from the AML/CFT Law administered by the Financial Monitoring Service (FMS) of Georgia 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
The NBG's AML/CFT supervision mandate is established under the Law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism," which designates specific obliged entities that the central bank must oversee AML / CFT Supervision.
The list of obliged entities supervised by NBG for AML/CFT purposes includes: non-bank deposit institutions (credit unions), currency exchange offices, commercial banks, microfinance organizations, brokerage companies, payment service providers, loan issuing entities, securities registrars, investment funds, virtual asset service providers (VASPs), and micro-banks (added starting July 1, 2023) AML / CFT Supervision.
The Financial Monitoring Service of Georgia is the state body responsible for the overall AML/CFT policy framework, and the Law of Georgia on Facilitating the Suppression of Money Laundering and the Financing of Terrorism (AML/CFT Law) is the foundational legislation governing all AML/CFT obligations, including those applicable to virtual asset service providers 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
The NBG publishes its regulatory framework for financial market participants, including securities market regulation, investment funds, brokerage companies, and related licensing rules, which collectively form the broader financial regulatory landscape within which VASPs must operate Regulatory Framework.
NBG's regulatory framework includes specific orders and decrees governing licensing of securities registrars, brokerage companies, asset management companies, and investment funds—these establish the administrative precedent for how NBG licenses and regulates financial entities under its jurisdiction Regulatory Framework.
The NBG is also responsible for approving the rules for determining, imposing, and enforcing monetary penalties against entities and members of their governing bodies for violations of securities legislation and the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism" Regulatory Framework.
Georgia's legal framework for aliens and stateless persons, governed by the Law of Georgia No. 2045-IIს of March 5, 2014, may be relevant to VASP licensing in terms of foreign ownership, management, and compliance personnel requirements, as this law regulates the legal status of non-Georgian nationals operating in the country ON THE LEGAL STATUS OF ALIENS AND STATELESS PERSONS.
The Organic Law of Georgia on the National Bank of Georgia establishes the legal basis for NBG's authority as the central bank and financial regulator, including its supervisory powers over financial institutions such as virtual asset service providers ORGANIC LAW OF GEORGIA ON THE NATIONAL BANK OF GEORGIA.
The NBG's regulatory framework page lists the Law of Georgia on Securities Market, the Law of Georgia on Investment Funds, the Law of Georgia on Mortgage Covered Bonds, and the Law of Georgia on Securitization as primary legal acts—these laws govern the broader financial markets within which crypto-related financial services may operate Regulatory Framework.
The supervisory approach of NBG toward VASPs is part of its AML/CFT supervision function, distinct from its securities market regulation, indicating that virtual asset providers are primarily regulated through the AML/CFT lens rather than through dedicated crypto-asset legislation AML / CFT Supervision.
There is no standalone virtual asset licensing framework published on NBG's regulatory framework page; instead, VASPs fall under the AML/CFT supervision regime, and the specific registration and authorization requirements must be derived from the AML/CFT Law and NBG's supervisory practice AML / CFT Supervision and Regulatory Framework.
For entities operating in the broader financial sector, NBG has established detailed licensing rules, such as Order N33/01 "On the approval of the Rules for Licensing the Securities Registrar," Order №145/04 "On approval of a rule of licensing and regulating of a brokerage company," and Decree №167/04 "On the Approval of the Rule on Licensing, Registration, Recognition and Regulation of an Asset Management Company" Regulatory Framework.
The NBG also regulates brokerage companies involved in trading with high-risk financial instruments under Order N107/04 "On the approval of the additional regulation rule of brokerage companies involved in trading with high-risk financial instruments," which may be relevant to crypto trading platforms offering brokerage-like services Regulatory Framework.
Specific capital requirements for VASP licensing are not published on the NBG's public regulatory framework pages; however, for similar financial entities, NBG has issued orders establishing minimum capital requirements, such as Order N33/01 concerning securities registrars Regulatory Framework.
The application process for VASP registration would be administered by the National Bank of Georgia, which maintains the AML/CFT supervision function and has the authority to supervise VASPs as obliged entities AML / CFT Supervision.
As of the current regulatory framework publications, there is no explicit public list of licensed virtual asset service providers on the NBG website, and the NBG's regulatory framework page focuses primarily on traditional securities market and investment fund licensing rather than on a dedicated VASP licensing regime Regulatory Framework.
The NBG's role in supervising VASPs is part of its AML/CFT mandate, meaning that registration as a VASP would involve demonstrating compliance with AML/CFT requirements, including establishing internal controls, policies, and procedures for preventing money laundering and terrorist financing AML / CFT Supervision and 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
Structural requirements for VASPs would likely include the appointment of a compliance officer, implementation of customer due diligence procedures, and establishment of transaction monitoring systems, consistent with the obligations imposed on other obliged entities supervised by NBG AML / CFT Supervision.
No specific public information exists on the NBG website indicating that any specific virtual asset service providers have been formally licensed or registered by NBG as of the date of the current regulatory framework publications AML / CFT Supervision and Regulatory Framework.
The Law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism" establishes the core AML/CFT obligations applicable to virtual asset service providers as obliged entities, including customer due diligence and reporting requirements 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
Obliged entities supervised by NBG, including VASPs, are required to report suspicious transactions to the Financial Monitoring Service of Georgia, the designated financial intelligence unit under the AML/CFT Law 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
The NBG has issued specific reporting orders for supervised entities, including Order №47/04 "On the approval of the rule for completing reports and presenting information for the legalization of illicit income of the Securities registrar and terrorist financing risk supervision" and Order №48/04 for brokerage companies, which set precedent for reporting obligations that would similarly apply to VASPs Regulatory Framework.
Record retention requirements for VASPs would be governed by the AML/CFT Law, requiring obliged entities to maintain customer identification data and transaction records for a specified retention period as established by the law 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
Beneficial ownership identification is a standard requirement under Georgia's AML/CFT regime, requiring obliged entities including VASPs to identify and verify the beneficial owners of legal entities that are their customers 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
Politically exposed persons (PEPs) screening is a component of the enhanced due diligence requirements under Georgia's AML/CFT framework, requiring obliged entities to apply EDD measures when dealing with foreign or domestic PEPs, which would apply to VASPs as obliged entities 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
The travel rule requirement, which mandates that VASP-to-VASP transfers include originator and beneficiary information, is embedded in the AML/CFT obligations of obliged entities under Georgia's AML/CFT framework, implemented through the Financial Action Task Force (FATF) standards transposed into the AML/CFT Law 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
NBG's AML/CFT supervision covers VASPs as a standalone category of obliged entities, indicating that NBG has the authority to examine VASP compliance with CDD, EDD, STR, and record-keeping obligations under the AML/CFT Law AML / CFT Supervision.
The NBG has the authority to impose monetary penalties against entities and members of their governing bodies for violations of the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism," as established under Order N35/04 of the President of the National Bank of Georgia Regulatory Framework.
The penalty framework under Order N35/04 covers violations of securities legislation, the Law of Georgia "On Accounting, Reporting and Auditing," and the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism" Regulatory Framework.
No specific enforcement actions against virtual asset service providers are published on the NBG's AML/CFT supervision page or regulatory framework page as of the current available information AML / CFT Supervision and Regulatory Framework.
No tax guidance has been issued for virtual assets in the sources provided.
The provided sources from the National Bank of Georgia and the Financial Monitoring Service do not include any tax treatment provisions for cryptocurrency gains, income tax, capital gains tax, or VAT applicable to virtual asset transactions The National Bank of Georgia and AML / CFT Supervision.
The regulatory framework publications focus exclusively on financial regulation, securities market rules, and AML/CFT supervision without addressing taxation of digital assets Regulatory Framework.
The absence of tax guidance in these official sources indicates that taxation of virtual assets in Georgia falls outside the published regulatory scope of NBG's financial and AML/CFT supervision framework, and tax matters would be governed separately by Georgia's Tax Code, which is not addressed in the provided materials 1 Law of Georgia on Facilitating the Suppression of Money Laundering and.
There is no dedicated, comprehensive crypto-asset law in Georgia; instead, virtual asset service providers are regulated solely through the AML/CFT supervision framework administered by NBG, creating regulatory uncertainty regarding licensing standards, capital requirements, and operational rules specifically tailored to crypto businesses AML / CFT Supervision and Regulatory Framework.
The travel rule implementation for crypto transfers in Georgia lacks publicly available specific thresholds, technical standards, and compliance guidance, as the NBG's published AML/CFT supervision page merely lists VASPs as obliged entities without detailing travel-rule obligations AML / CFT Supervision.
There is no public evidence of any virtual asset service provider having been licensed or registered by NBG, indicating that the practical reality for crypto businesses in Georgia may involve operating in a regulatory gray area where formal authorization is unclear or not yet operationalized AML / CFT Supervision and Regulatory Framework.
The legal framework for aliens and stateless persons introduces additional compliance considerations for foreign-owned VASPs, as non-Georgian nationals involved in crypto businesses must comply with visa, residence permit, and employment regulations under the Law on the Legal Status of Aliens and Stateless Persons, adding compliance complexity for international crypto operators ON THE LEGAL STATUS OF ALIENS AND STATELESS PERSONS.
The absence of published enforcement actions against VASPs suggests either a lack of active VASP supervision or a nascent enforcement regime, representing a regulatory gap where non-compliant crypto businesses may operate without immediate consequences AML / CFT Supervision and Regulatory Framework.
Businesses face the risk that the current AML/CFT-based approach may be superseded by more comprehensive crypto-asset regulation in the future, requiring VASPs to adapt their compliance frameworks as Georgia develops its virtual asset legislation in line with international standards AML / CFT Supervision.
The lack of tax guidance for virtual assets in the official regulatory sources creates tax compliance uncertainty for crypto businesses, who cannot determine with certainty how their crypto revenue and gains will be treated for income tax, VAT, or capital gains purposes in Georgia The National Bank of Georgia and Regulatory Framework.
1 Law of Georgia on Facilitating the Suppression of Money Laundering and
ON THE LEGAL STATUS OF ALIENS AND STATELESS PERSONS
ORGANIC LAW OF GEORGIA ON THE NATIONAL BANK OF GEORGIA
On Approval of the List of Countries Whose Citizens May Enter Georgia without a Visa
Law of Georgia on Tourism and Resorts
National Bank of Georgia (NBG) – Regulates VASPs and enforces AML/CFT standards.
Ministry of Finance – Oversees tax legislation, including crypto-related income taxation.
Financial Monitoring Service (FMS) – Receives suspicious transaction reports from VASPs.
Virtual Asset Services Regulation (NBG Decree No. 94/04): Mandates registration and supervision of VASP activities in Georgia.
Tax Code of Georgia (Section I General Provisions): Defines taxable income sources and exemptions for non-Georgian sourced income.
Small Business Tax Policy, Informality, and Tax Evasion – Evidence from Georgia
Georgia - Individual - Taxes on personal income
Tax Reform in Georgia and the Size of the Shadow Economy
Tax Rules and Policies | Department of Revenue - Georgia.gov
Income Tax Regulations | Department of Revenue - Georgia.gov
Taxes - Department of Revenue - Georgia.gov
Department of Revenue - Georgia.gov
Sales & Use Tax Regulations | Department of Revenue
TAX CODE OF GEORGIA | სსიპ ”საქართველოს ...
LAW OF GEORGIA TAX CODE OF GEORGIA SECTION I GENERAL PROVISIONS
Cultural and Creative Tax Incentives -A Cross-Border Legal and Regulatory Framework
Crypto Licence In Georgia 2026 — NBG VASP Registration
GeoExperts — Business in Georgia: documents, taxes, accounting
Do fairness perceptions influence moral licensing behavior? Evidence from tax compliance
Regulating the Borderless: AML, Tax, and Jurisdictional Challenges of Cross-Border DeFi for U.S. Participants
claim Cryptocurrency activities in Georgia are regulated by the National Bank of Georgia (NBG) through a VASP registration regime established on 1 January 2023. Crypto Licence In Georgia 2026 — NBG VASP Registration
claim Personal income from crypto investments is exempt for Georgian residents under Ministry of Finance clarifications. Georgia - Individual - Taxes on personal income
claim Corporate profits are taxed only on distribution at a 15% rate plus a 5% dividend withholding tax in Georgia. Tax Code of Georgia Section I General Provisions
claim No EU market access is provided by Georgian VASP registration; MiCA authorisation is required for serving EU clients. Crypto Licence In Georgia 2026 — NBG VASP Registration
claim The state fee for a Georgian VASP licence is approximately GEL 5,000 as of 2025. Crypto Licence In Georgia 2026 — NBG VASP Registration
Key Takeaway: The GDBF views virtual currencies as "money" or "monetary value" for the purposes of the Money Transmission Act when they are used as a medium of exchange. Therefore, activities involving the transmission or holding of virtual currency on behalf of others may require a money transmitter license.
No specific "custodial license" for digital assets.
Money Transmitter License (MTL): If a business engages in the "transmission of money" or "receiving money or monetary value for transmission" on behalf of others, including virtual currency, it is likely required to obtain a Money Transmitter License from the GDBF.
The requirement for a money‑transmitter license to sell, issue, or transmit virtual currency in Georgia remains enforceable under O.C.G.A. § 7‑1‑681(b), but the specific GDBF advisory wording quoted in the claim is not found in current Georgia‑specific sources.
Relevant Statute: O.C.G.A. § 7-1-681(a)(11) defines "money transmission" broadly.
Licensing Authority: Georgia Department of Banking and Finance (GDBF)
Application Process: Managed through the Nationwide Multistate Licensing System & Registry (NMLS).
No explicit crypto-specific asset segregation rules.
Implicit Requirements from MTL: While not explicitly detailing crypto asset segregation, the Georgia Money Transmission Act does require licensees to maintain certain financial standards to ensure the protection of customer funds.
Permissible Investments: O.C.G.A. § 7-1-686 requires licensees to maintain "permissible investments" (such as cash, government securities, etc.) with an aggregate market value at least equal to the aggregate amount of all outstanding money transmission obligations in Georgia. This ensures liquidity to cover customer claims, even if not strict asset-specific segregation.
The GDBF, in its supervisory role, would expect sound internal controls and accounting practices to clearly distinguish customer assets from company assets, regardless of explicit crypto-specific rules.
Surety Bond: Holders of a Georgia Money Transmitter License are required to obtain a surety bond.
Statutory Basis: O.C.G.A. § 7-1-683 outlines the application requirements, which include securing a surety bond.
Amount: The minimum bond amount is typically $250,000, and it can be increased by the Commissioner based on the licensee's volume of money transmission activity, not to exceed $2,000,000.
The GDBF Advisory also references these bond requirements.
No specific mandate for cold storage in Georgia's current laws or guidance.
Cold storage is no longer considered the primary industry best practice for securing digital assets under current Georgia cybersecurity regulations, which now emphasize multi-factor authentication and real-time monitoring.
No specific "qualified custodian" definition within Georgia state law for digital assets.
Federal Context: The term "qualified custodian" is primarily defined at the federal level by the U.S. Securities and Exchange Commission (SEC) under the Custody Rule (Rule 206(4)-2 of the Investment Advisers Act of 1940). This rule applies to SEC-registered investment advisers and requires them to hold client funds and securities with a "qualified custodian."
While Georgia doesn't have its own definition for crypto, if a firm operating in Georgia is also an SEC-registered investment adviser and custodies digital assets that are considered "securities," then the federal "qualified custodian" requirements would apply to that firm.
A qualified custodian under federal law generally includes banks, savings associations, registered broker-dealers, and registered futures commission merchants. For digital assets, the application of this definition is complex and still evolving at the federal level.
As of my last update (early 2024), there is no specific, comprehensive digital asset custody legislation actively moving through the Georgia General Assembly that would create a distinct licensing framework or specific rules for digital asset custodians (like those seen in states such as Wyoming or New York).
Legislative activity often focuses on broader blockchain studies, pilot programs, or minor amendments to existing financial laws. However, the legislative landscape is dynamic, and it's always advisable to check the current session's legislative trackers (e.g., Georgia General Assembly website) for the latest information.
Consult the Georgia Department of Banking and Finance's official website and advisories.
Seek legal counsel specializing in financial services and cryptocurrency regulation in Georgia to ensure full compliance, as interpretations and legislative efforts can evolve.
E-money Tokens (EMTs): Virtual assets that purport to maintain a stable value by referencing the value of one fiat currency. These are akin to electronic money and fall under the definition of "electronic money" as per MiCA if they meet certain criteria.
Asset-Referenced Tokens (ARTs): Virtual assets that purport to maintain a stable value by referencing any other value or right, or a combination thereof, including one or several official currencies, commodities, or other crypto-assets.
Other Virtual Assets: If a stablecoin does not fit the EMT or ART definitions (e.g., an unbacked algorithmic stablecoin), it would generally be treated as a generic "virtual asset" under the LoVA, potentially making its issuance and operation much more difficult or impossible under the licensing regime for stablecoins, as the law focuses on asset-backed tokens. If it represents a share in a company or a debt instrument, it could fall under existing Georgian securities laws.
While an official English translation of the final enacted law is not immediately available from a Georgian government source, the bill version and numerous legal analyses confirm its MiCA alignment regarding ARTs and EMTs.
Unofficial reference for context: PwC Legal Alert on LoVA (referencing the bill, final law is largely similar)
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.
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.
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).
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.
The NBG will issue specific regulations detailing the application process, required documentation, and ongoing obligations.
Official NBG website (for future regulations): National Bank of Georgia
E-money Tokens (EMTs): Holders generally have the right to redeem their tokens at par value for the underlying fiat currency from the issuer at any time.
Asset-Referenced Tokens (ARTs): Holders have the right to redeem their tokens from the issuer, either directly for the underlying reserve assets (or a portion thereof) or for a fiat equivalent, based on the terms outlined in the stablecoin's whitepaper and NBG regulations. The issuer must ensure sufficient liquidity in the reserve to meet redemption requests.
Unbacked Algorithmic Stablecoins: Stablecoins that rely solely on algorithms and arbitrage mechanisms to maintain their peg, without significant and verifiable asset backing, would likely not qualify as either EMTs or ARTs under the LoVA's definitions. This would make it extremely challenging, if not impossible, to obtain a license for their issuance or operation in Georgia as a regulated "stablecoin."
The focus of the LoVA and NBG regulations will be on stablecoins with robust, identifiable, and auditable reserve assets, thereby mitigating risks associated with highly volatile or collapsing algorithmic models.
Law of Georgia on Virtual Assets (LoVA), by defining ARTs and EMTs based on asset backing, implicitly excludes unbacked algorithmic stablecoins from these regulated categories, placing them in a regulatory gray area or making them unfeasible for licensed operation.
Project Status: In September 2023, the NBG announced the launch of a pilot project for the Digital Lari with private sector participants.
Nature: The Digital Lari, if fully implemented, would be a direct liability of the NBG, representing a digital form of the national currency. It would be fundamentally different from private stablecoins, which are liabilities of private issuers.
Coexistence: A Digital Lari could coexist with regulated private stablecoins, offering an official, risk-free digital payment option alongside private sector innovations.
Competition: It might also compete with stablecoins, especially those referencing the Georgian Lari (EMTs), by offering a more secure and trusted alternative.
Regulatory Separation: The legal framework for a Digital Lari would likely be established under the NBG's powers related to currency issuance, separate from the LoVA which governs private virtual assets.
National Bank of Georgia Press Release on Digital Lari Pilot: NBG Launches Digital Lari Pilot Project (September 2023)
Cryptocurrency and digital asset securities in Georgia fall under the regulatory oversight of the National Bank of Georgia (NBG), which serves as the primary financial sector regulator, including for securities market activities Regulatory Framework.
The legal framework is built on the Law of Georgia on Securities Market, which governs securities offerings, licensing of market participants, and ongoing compliance obligations LAW OF GEORGIA ON SECURITIES MARKET.
Licensing is available for securities market participants such as brokerage companies, securities registrars, asset management companies, and investment funds through NBG-issued orders and decrees Regulatory Framework.
No specific cryptocurrency or digital asset securities licenses have been publicly confirmed as granted by NBG as of the latest available official documentation, meaning the practical reality is that digital asset firms face uncertainty regarding applicability of existing securities rules Supervision.
The National Bank of Georgia (NBG) is the primary financial sector regulator and has supervisory authority over commercial banks, banking groups, non-bank depository institutions, brokerages, independent securities registrars, asset management companies, central depositories, specialized depositories, founders of non-government pension schemes, stock exchanges, microfinance institutions, payment service providers, accountable enterprises, currency exchange bureaus, credit information bureaus, and lending entities Supervision.
The NBG's regulatory mandate is derived from the Organic Law of Georgia on the National Bank of Georgia, which tasks the NBG with promoting financial stability and transparency of the financial sector, protecting the rights of consumers and investors, and promoting the stable and efficient functioning of the financial system Supervision.
The central piece of legislation for securities regulation in Georgia is the Law of Georgia on Securities Market, which governs public offerings, securities issuance, registration requirements, and market conduct LAW OF GEORGIA ON SECURITIES MARKET.
Additional legal acts governing securities-related matters include Order N178/04 of the President of the National Bank of Georgia approving the list of recognized stock exchanges of foreign countries and rules related to public offerings of securities in Georgia by international financial institutions Regulatory Framework.
The Law of Georgia on Commercial Bank Activities is a separate but relevant legal instrument for entities operating in the banking and financial sector in Georgia, including provisions on licensing and prudential requirements LAW OF GEORGIA ON COMMERCIAL BANK ACTIVITIES Chapter I General Provisions.
The NBG has issued Order N107/04 on additional regulation rules for brokerage companies involved in trading with high-risk financial instruments, which may have relevance to digital asset trading activities Regulatory Framework.
Order N180/04 of the Governor of the National Bank of Georgia addresses insider dealing, unlawful disclosure of inside information, and market manipulation, which would apply to digital asset securities if they fall within the definition of securities under Georgian law Regulatory Framework.
The NBG has approved the Corporate Governance Code for Issuers of Public Securities via Decree N172/04, which sets governance standards applicable to public securities issuers Regulatory Framework.
Order N197/04 establishes rules on granting, maintenance, and cancellation of Green, Social, Sustainability, and Sustainability-linked Bond Status, indicating the NBG's recognition of specialized securities categories Regulatory Framework.
The NBG conducts ongoing supervisory reforms and maintains compliance with international best practices, with its financial sector oversight assessed by the International Monetary Fund and the World Bank under the Financial Sector Assessment Program (FSAP) Supervision.
The NBG is also assessed by international organizations including the International Monetary Fund (IMF), the European Bank for Reconstruction and Development (EBRD), rating agencies (Moody's, Fitch Ratings), the World Bank, and the Asian Development Bank Supervision.
Capital market supervision is a distinct area within NBG's supervisory framework, covering securities market participants and activities Capital Market Supervision.
The NBG's regulatory framework for securities includes orders and decrees on licensing, reporting, transparency, sanctions, investment funds, funded pension schemes, and other areas Regulatory Framework.
Georgia's securities legislation includes the Law of Georgia on Securities Market, which has been subject to ongoing amendments and implementation through NBG orders LAW OF GEORGIA ON SECURITIES MARKET.
The NBG issues licenses for securities market participants, including "brokerage company" licenses, as governed by Order №145/04 of the President of the National Bank of Georgia on approval of the rule of licensing and regulating of a brokerage company Regulatory Framework.
Independent securities registrars require licensing under Order N33/01 of the President of the National Bank of Georgia, which sets rules for licensing the securities registrar, submitting financial statements, determining the minimum amount of capital, and terminating activities of the securities registrar Regulatory Framework.
Asset management companies are subject to licensing, registration, recognition, and regulation under Decree №167/04 of September 22, 2020 of the Governor of the National Bank of Georgia, "On the Approval of the Rule on Licensing, Registration, Recognition and Regulation of an Asset Management Company" Regulatory Framework.
Investment funds require authorization, registration, recognition, and regulation under Decree №170/04 of September 22, 2020 of the Governor of the National Bank of Georgia, "On the Approval of the Rule on Authorization, Registration, Recognition and Regulation of an Investment Fund" Regulatory Framework.
Specialized depositaries must be approved under Decree №168/04 of September 22, 2020 of the Governor of the National Bank of Georgia, "On the Approval of the Rule of Activities of the Specialized Depositary" Regulatory Framework.
The organized market recognition process is set out in Order N33/04 of the President of the National Bank of Georgia, dated February 20, 2018, "On the Approval of the Rules for Recognition of the Financial Instruments Trading System as an Organized Market" Regulatory Framework.
Investment fund unit owner registries must be maintained according to Order N169/04 of the President of the National Bank of Georgia, "On Approving the Rule for Keeping Registry of Investment Fund Unit Owners" Regulatory Framework.
Investment fund liquidation is governed by Order N198/04 of the President of the National Bank of Georgia, "On Approving the Liquidation Rule of the Investment Fund" Regulatory Framework.
For pension asset management, Order N257/04 of the President of the National Bank of Georgia, dated November 30, 2018, establishes additional requirements for pension asset management Regulatory Framework.
The NBG's supervisory remit explicitly includes stock exchanges, brokerage firms, independent securities registrars, asset management companies, central depositories, and specialized depositories, all of which require appropriate licensing or registration Supervision.
The securities registrar must comply with reporting requirements for anti-money laundering and terrorist financing risk supervision as set out in Order №47/04 of the President of the National Bank of Georgia Regulatory Framework.
Brokerage companies must comply with Order №48/04 of the President of the National Bank of Georgia on the approval of rules for completing reports and presenting information for the legalization of illicit income and terrorist financing risk supervision Regulatory Framework.
As of the latest available information from official NBG pages, no specific digital asset or cryptocurrency exchange has been publicly confirmed as having obtained a securities license from the NBG, and no dedicated virtual asset licensing regime has been published by the NBG Regulatory Framework.
Securities registrars in Georgia are required to complete reports and present information for the legalization of illicit income and terrorist financing risk supervision, as mandated by Order №47/04 of the President of the National Bank of Georgia Regulatory Framework.
Brokerage companies must complete reports and present information for the legalization of illicit income and terrorist financing risk supervision under Order №48/04 of the President of the National Bank of Georgia Regulatory Framework.
Brokerage companies involved in trading with high-risk financial instruments are subject to additional regulation under Order N107/04 of the National Bank of Georgia, which implies enhanced scrutiny and potentially more stringent due diligence obligations Regulatory Framework.
The NBG's sanction framework under Order N35/04 includes violations of the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism," which covers AML compliance obligations for securities market participants Regulatory Framework.
The NBG has the authority to determine, impose, and enforce monetary penalties against entities and members of their governing bodies for violations of securities legislation, the Law of Georgia "On Accounting, Reporting and Auditing," and the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism," as outlined in Order N35/04 Regulatory Framework.
The NBG's enforcement and penalty framework for securities legislation violations is established under Order N35/04 of the President of the National Bank, which outlines rules for determining, imposing, and enforcing monetary penalties against entities and members of their governing bodies for violations of securities legislation and related laws Regulatory Framework.
No publicly reported enforcement actions specifically involving digital asset securities or cryptocurrency firms in Georgia were identified in the provided source materials Regulatory Framework.
No tax guidance has been issued for virtual assets.
The provided source materials from the National Bank of Georgia do not contain any specific tax treatment provisions or guidance for cryptocurrency or digital asset securities Regulatory Framework.
The existing securities regulatory framework in Georgia does not explicitly address digital assets or cryptocurrency securities, creating uncertainty regarding whether and how these instruments fall under the Law of Georgia on Securities Market LAW OF GEORGIA ON SECURITIES MARKET.
No dedicated virtual asset service provider (VASP) licensing regime or specific digital asset regulatory framework has been published by the NBG, meaning businesses dealing in digital asset securities in Georgia face legal uncertainty Regulatory Framework.
The NBG's enforcement powers under Order N35/04 exclusively apply to violations under securities legislation, accounting rules, and AML/CFT law, but do not explicitly address digital asset-specific violations Regulatory Framework.
High-risk financial instruments regulation via Order N107/04 may potentially capture certain digital asset trading activities conducted by brokerage companies, but the scope of application remains unclear without explicit digital asset definitions Regulatory Framework.
The NBG's list of supervised entities does not explicitly include virtual asset exchanges or digital asset custodians, creating a supervisory gap for crypto-related businesses Supervision.
For a business seeking to operate a digital asset securities platform in Georgia, the lack of explicit regulatory clarity means that firms must make their own assessments as to whether their operations constitute "securities market" activity requiring a license under the Law of Georgia on Securities Market LAW OF GEORGIA ON SECURITIES MARKET.
The NBG has no documented track record of licensing or supervising digital asset-specific entities, which means that the practical reality of obtaining regulatory approval for a digital asset securities business in Georgia is untested and potentially subject to significant regulatory delays or refusals Regulatory Framework.
The regulatory framework for securities in Georgia does not mention "digital assets," "cryptoassets," "virtual currencies," "tokens," or "blockchain" in any of the publicly listed legal acts on the NBG's regulatory framework page, representing a significant gap in the legislative framework Regulatory Framework.
Because Georgia's securities laws have not yet clarified the treatment of digital assets, there is a risk that a digital asset classified as a security under Georgian law would be subject to the full securities regulatory framework designed for traditional instruments, including prospectus requirements, licensing of intermediaries, and ongoing disclosure obligations LAW OF GEORGIA ON SECURITIES MARKET.
LAW OF GEORGIA ON COMMERCIAL BANK ACTIVITIES Chapter I General Provisions
LAW OF GEORGIA ON SECURITIES MARKET
National Bank of Georgia (NBank) – Responsible for financial regulation and compliance with external sanctions. Website: nbg.gov.ge
UN Sanctions Compliance – Georgia implements United Nations sanctions. Source: GlobalSanctions.com/Region/Gorgia
No autonomous sanctions list; relies on international regimes. Source: Castellum.AI/Georgia-Sanctions-Guide
Georgia adheres to UN and EU sanctions, aligning with FATF recommendations but without a separate autonomous list. Source: NBank Regulation Amendment
No specific license for cryptocurrency businesses in Georgia; compliance with financial services regulations applies broadly.
Financial institutions, including those involved in crypto transactions, must comply with NBK licensing for banking activities. Source: NBank Regulation Amendment
Not applicable to cryptocurrency services directly; however, financial institutions must meet NBK capital adequacy standards.
No dedicated crypto license process; general banking/financial licensing procedures apply.
Entities must be registered with the State Registration Chamber of Georgia and comply with AML/KYC obligations.
No specific cryptocurrency licenses have been issued as of 2025-2026. Source: NBank Regulation Amendment
Financial institutions must conduct Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk customers, including crypto exchanges. Suspicious Transaction Reports (STRs) are mandatory when suspicious activity is detected. Source: Finanšu Izlūkošanas Dienests FAQ
Records of customer identities and transaction histories must be retained for at least five years.
Transparency of beneficial ownership is required for legal entities, including those in the crypto sector.
Politically Exposed Persons (PEPs) require additional scrutiny under AML policies.
Non-compliance with sanctions or AML/KYC can result in fines and potential criminal liability. Georgian courts may impose penalties for evasion attempts. Source: NBank Regulation Amendment
No specific arrests or enforcement actions reported directly against cryptocurrency firms as of 2025, but sanctions evasion attempts are monitored closely.
EU Parliament Calls for Sanctions on Georgia and its Leaders | OCCRP
Georgia risks becoming Russian sanctions-evasion haven
Guide to Georgia's Sanctions List — Castellum.AI
Western sanctions will deepen divide with Georgia
Promoting the Use of Non-custodial Sanctions in Armenia, Azerbaijan and Georgia
Regulation on Compliance with Sanctions Regimes Amended
Reverse Sanctions Evasion: The Case of Russian Oil Re-exports to the European Union via Georgia
Cryptocurrency activities in Georgia are subject to UN and EU sanctions, with no autonomous list. Georgia | Global Sanctions
The National Bank of Georgia (NBank) ensures compliance with external sanctions regimes. Regulation on Compliance with Sanctions Regimes Amended
Georgian citizens can be sanctioned only post a guilty verdict in Georgian courts. NBank Regulation Amendment
No specific licensing regime for cryptocurrency businesses exists in Georgia as of 2025-2026.
AML/KYC requirements include CDD, EDD, STR reporting, and beneficial ownership transparency. Finanšu Izlūkošanas Dienests FAQ
Tax treatment for crypto gains is unspecified, leading to potential ambiguity. NBank Regulation Amendment
National Bureau of Enforcement (NBE): Responsible for enforcing general laws across Georgia.
National Bank of Georgia (NBG): Oversees financial sector compliance, including indirect oversight of crypto-related activities via existing financial regulations.
Georgia Access to Medical Cannabis Commission (GAMCC): Regulates low‑THC oil but not broader cryptocurrency markets.
Law of Georgia on Enforcement Proceedings (1999): Governs enforcement across judicial and administrative acts, including those related to financial offenses. Source
National Bank of Georgia Competition Policy: Addresses market manipulation and unfair practices that could affect crypto trading platforms. Source
NBG Oversight: Crypto platforms may be classified under securities or payment system licensing if they facilitate tokenized assets or fiat conversions.
Application Process: Not applicable without a specific crypto license; entities would need to apply for general banking or payment licenses per NBG rules. Source
Capital Requirements: Vary by the type of financial service but generally require meeting NBG’s minimum capital standards.
Actual Licensing Status: No crypto‑specific licenses have been issued; existing licensed entities operate under broader categories.
Likely new licensing requirements expected around 2026-12-03
Based on 100 historical regulatory events for Georgia, averaging every 73 days, with increasing regulatory activity.
Regulator/Enforcement Body: Investigative Committee of Armenia, Prosecutor General's Office of Armenia, often in cooperation with law enforcement agencies from other countries (e.g., Russia, Georgia, US).
Federal Context: The term "qualified custodian" is primarily defined at the federal level by the U.S. Securities and Exchange Commission (SEC) under the Custody Rule (Rule 206(4)-2 of the Investment Advisers Act of 1940). This rule applies to SEC-registered investment advisers and requires them to hold client funds and securities with a "qualified custodian."
Legislative activity often focuses on broader blockchain studies, pilot programs, or minor amendments to existing financial laws. However, the legislative landscape is dynamic, and it's always advisable to check the current session's legislative trackers (e.g., Georgia General Assembly website) for the latest information.
National Bank of Georgia (NBG): The central bank is the sole licensing and supervisory authority for VASPs in Georgia.
Unregistered Offerings: Issuing tokens deemed securities without proper registration or an applicable exemption is a violation. The DBF would issue cease-and-desist orders, levy fines, and seek injunctive relief.
Unlicensed Broker-Dealer Activity: Individuals or entities acting as broker-dealers for security tokens without proper state registration would be subject to enforcement.
Georgia Department of Banking and Finance (DBF) - Securities Division: This is the primary regulatory body responsible for administering and enforcing Georgia's securities laws. While they generally don't issue crypto-specific guidance beyond applying existing law, their website provides information on securities registration, exemptions, and compliance.
National Bank of Georgia (NBG): This is the primary regulator responsible for the licensing, supervision, and regulation of Virtual Asset Service Providers (VASPs). The NBG issues secondary legislation (rules, decrees) to implement the VASP law.
Licensing is Mandatory: As of March 1, 2024, entities operating as Virtual Asset Service Providers (VASPs) in Georgia are required to obtain a license from the National Bank of Georgia (NBG). This includes:
Penalties for Non-Compliance: Operating as a VASP without a license can lead to significant penalties, including fines and potential criminal charges.
Individual Trading: The VASP Law primarily targets service providers. Individual participation in virtual asset trading for personal use is not banned, but individuals engaging with unlicensed VASPs do so at their own risk. All transactions with licensed VASPs, however, will be subject to the VASP's AML/CFT procedures.
The amendments to Georgia's AML/CFT Law bringing VASPs under its scope became effective earlier.
Manual Exemption (O.C.G.A. § 10-5-10(10)): Securities are exempt if current issuer information is published in recognized securities manuals (e.g., Moody's, S&P), though less common for emerging crypto projects Manual Exemption
Unregistered Offerings: Issuing tokens deemed securities without registration or exemption violates state law. The DBF can issue cease-and-desist orders, levy fines, and seek injunctive relief Unregistered Offerings Enforcement
Legislative Activity: Georgia's legislative landscape regarding crypto focuses on broader blockchain studies and minor amendments to existing financial laws, though the landscape remains dynamic Georgia Crypto Legislation
National Bank of Georgia (NBG): Responsible for licensing and supervising banks in Georgia. Website: https://nbg.gov.ge/en
Organic Law "On the National Bank of Georgia" (No. 552-XII, adopted in 1993): Grants NBG its regulatory authority.
The National Bank of Georgia for Financial Stability
Securing a Banking License in Georgia: Legal Frameworks and Regulatory Approval
Cryptocurrencies and digital assets fall under the regulatory purview of the NBG in Georgia. The National Bank of Georgia for Financial Stability
A minimum capital requirement of 50 million GEL is mandated for obtaining a banking license. Securing a Banking License in Georgia: Legal Frameworks and Regulatory Approval
No specific licenses are issued exclusively for cryptocurrency or digital asset activities; general banking licenses apply. Securing a Banking License in Georgia: Legal Frameworks and Regulatory Approval
The NBG oversees licensing, prudential supervision, corporate governance regulation, regulatory compliance monitoring, and stabilization measures within the banking sector. The National Bank of Georgia for Financial Stability
Central Bank of Georgia – oversees monetary policy and banking activities; has issued guidance on virtual asset service providers (VASPs).
Regulation of the Central Bank of Georgia “On Virtual Asset Service Providers (VASPs)” – adopted in March 2023; references FATF standards but does not grant a specific license type for crypto exchanges.
Central Bank of Georgia – Regulation on VASPs (2023)
Cryptocurrencies are legal in Georgia but lack a dedicated regulatory framework. National Agency of Financial Market
No cryptocurrency exchange has been officially licensed by the NAFM as of October 2025. Central Bank of Georgia Regulation on VASPs (2023)
National Bureau of Enforcement (NBE): Responsible for enforcing general laws across Georgia.
National Bank of Georgia (NBG): Oversees financial sector compliance, including indirect oversight of crypto-related activities via existing financial regulations.
Law of Georgia on Enforcement Proceedings (1999): Governs enforcement across judicial and administrative acts, including those related to financial offenses. Source
National Bank of Georgia Competition Policy: Addresses market manipulation and unfair practices that could affect crypto trading platforms. Source
The National Bank of Georgia (NBG) oversees the licensing and supervision of virtual asset service providers (VASPs) to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) regulations. The National Bank of Georgia for Financial Stability
Licensed VASPs are required to implement robust customer identification and verification processes, including Know Your Customer (KYC) procedures and ongoing monitoring of transactions for suspicious activity. The National Bank of Georgia for Financial Stability
National Bank of Georgia (NBank) – Responsible for financial regulation and compliance with external sanctions. Website: nbg.gov.ge
UN Sanctions Compliance – Georgia implements United Nations sanctions. Source: GlobalSanctions.com/Region/Gorgia
No autonomous sanctions list; relies on international regimes. Source: Castellum.AI/Georgia-Sanctions-Guide
Georgia adheres to UN and EU sanctions, aligning with FATF recommendations but without a separate autonomous list. Source: NBank Regulation Amendment
Reverse Sanctions Evasion: The Case of Russian Oil Re-exports to the European Union via Georgia
Promoting the Use of Non-custodial Sanctions in Armenia, Azerbaijan and Georgia
EU Parliament Calls for Sanctions on Georgia and its Leaders | OCCRP
Georgia risks becoming Russian sanctions-evasion haven
Guide to Georgia's Sanctions List — Castellum.AI
Western sanctions will deepen divide with Georgia
Cryptocurrency activities in Georgia are subject to UN and EU sanctions, with no autonomous list. Georgia | Global Sanctions
The National Bank of Georgia (NBank) ensures compliance with external sanctions regimes. Regulation on Compliance with Sanctions Regimes Amended
No specific licensing regime for cryptocurrency businesses exists in Georgia as of 2025-2026.
National Bank of Georgia (NGB) – https://nbg.gov.ge/en/page/regulatory-laboratory
Primary Law: “Creation and Use of a Regulatory Sandbox Framework by the National Bank of Georgia,” approved by Order No. 125/04, dated May 23, 2025.
Who regulates? The National Bank of Georgia (NGB).
National Bank of Georgia (NBG) – Regulates VASPs and enforces AML/CFT standards.
Tax Code of Georgia (Section I General Provisions): Defines taxable income sources and exemptions for non-Georgian sourced income.
claim Cryptocurrency activities in Georgia are regulated by the National Bank of Georgia (NBG) through a VASP registration regime established on 1 January 2023. Crypto Licence In Georgia 2026 — NBG VASP Registration
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