Georgia Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Bank of Georgia Resolution No, Ministry of Finance
Primary Legislation: This is the foundational law. It sets out the definition of VASPs, the requireme, This resolution provides the detailed rules for how the Law on Virtual Assets is, AML/CFT Law, This law governs the general AML/CFT obligations for all obligated entities in G, VASP Law, NBG Statement on Adoption of VASP Law (July 2023), s VASP Law (March 2024) (Provides a good overview of the law, The NBG regulates securities markets under the Law of Georgia on Securities Mark, The Law of Georgia on Investment Funds, the Law of Georgia on Mortgage Covered B, Decree N167/04 of September 22, 2020, of the Governor of the NBG approves the Ru, Decree N170/04 of September 22, 2020, of the Governor of the NBG approves the Ru, Additional regulation applies to brokerage companies involved in trading with hi, The regulatory framework page does not list any dedicated virtual asset law, reg, ORGANIC LAW OF GEORGIA ON THE NATIONAL BANK OF GEORGIA, Georgia does not have a specific law addressing virtual assets, and the existing, The main legal acts governing financial activities include the Law of Georgia on, The Organic Law of Georgia on the National Bank of Georgia establishes the NBG's, Decree N172/04 of the President of the NBG approves the Corporate Governance Cod, Decree №167/04 of September 22, 2020, of the Governor of the NBG approves rules, Decree №168/04 of September 22, 2020, of the Governor of the NBG approves rules, Decree №170/04 of September 22, 2020, of the Governor of the NBG approves rules, Georgia does not have a dedicated virtual asset law, digital asset regulation, o, For brokerage companies, licensing and regulation rules are approved under Order, Order N107/04 of the National Bank of Georgia approves additional regulation rul, Georgia's practical reality differs significantly from paper law, as crypto trad
Travel Rule: Not adopted
Tax Reporting: 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.

Key Facts

aml 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.
banking National Bank of Georgia (NBG): Responsible for licensing and supervising banks in Georgia. Website: https://nbg.gov.ge/en Law "On the Activities of Commercial Banks" (No. 2009, adopted by Parliament): Governs banking operations. Organic Law "On the National Bank of Georgia" (No. 552-XII, adopted in 1993): Grants NBG its regulatory authority. Capital management on behalf of clients Submit a detailed business plan. Provide proof of capital source and amount. Conduct fit-and-proper assessments for administrators and shareholders. Ensure IT infrastructure meets security standards.
cross border Central Bank of Georgia – oversees monetary policy and banking activities; has issued guidance on virtual asset service providers (VASPs). Law of Georgia “On the National Agency of Financial Market” – No. 2018‑Z‑33, effective 1 July 2018. 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. Conducting ICOs or token sales. Customer Due Diligence (CDD): Identify and verify customers’ identities on first deposit; ongoing monitoring for suspicious activity. Enhanced Due Diligence (EDD): Required for high‑risk customers, including politically exposed persons (PEPs). Simplified Due Diligence (SDD): May apply to low‑value transactions (< EUR 10 000) after satisfactory risk assessment. Suspicious Transaction Reporting (STR): Submit STRs within 5 business days to the NAFM for any transaction or series of transactions exceeding risk thresholds.
custody 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.
enforcement 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.
general An investment of money (or other valuable consideration): This is generally met when purchasers pay for tokens. In a common enterprise: This typically means that the fortunes of the investor are interwoven with those of the promoter or third parties. In the crypto context, this is often the success of the issuer's platform, network, or project. With an expectation of profit: Investors must be looking for a financial return on their investment. This excludes tokens bought purely for consumption or utility without a profit motive. To be derived primarily from the efforts of others: The profits must come substantially from the managerial or entrepreneurial efforts of the issuer or a third party, rather than the efforts of the investor. (Note: The "solely" from Howey has been broadened to "primarily" or "significant efforts" by subsequent case law). Investment Contract Tokens (Security Tokens): Tokens offered in an Initial Coin Offering (ICO) or Security Token Offering (STO) where purchasers invest with the expectation that the value of the token will appreciate due to the efforts of the issuer or a third party (e.g., developing a platform, marketing, managing the network). This includes most pre-functional or underdeveloped "utility tokens" sold primarily for speculative purposes. Tokens Linked to an Enterprise's Success: Tokens whose value is directly tied to the success of a specific company, project, or platform developed and managed by an identifiable group. Fractionalized Assets: Tokens representing ownership stakes in real-world assets (e.g., real estate, art, company equity) are typically securities. True Utility Tokens (Post-Functionality): If a token is sold primarily for its immediate consumption or use within a fully developed and decentralized network (e.g., for accessing a service, paying fees) and not primarily as an investment for profit from the efforts of others, it may not be a security. However, the initial sale of even a true utility token can be deemed a security if sold with an investment expectation.
licensing 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. 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.
ongoing VASPs operating in Georgia must obtain a license from the NBG, which involves submitting detailed information about their business model, risk management procedures, and compliance mechanisms. Georgia Crypto License & VASP Registration Support 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 The NBG has the authority to impose fines, suspend or revoke licenses, and take other enforcement measures against VASPs that fail to comply with regulatory requirements. Georgia Crypto License & VASP Registration Support Cryptocurrency transactions in Georgia are subject to income tax on profits derived from trading activities, and capital gains tax may apply depending on the nature of the asset. Georgia Crypto License & VASP Registration Support One key gap is the evolving global regulatory landscape, which poses challenges for Georgian authorities to keep pace with international standards. Additionally, the potential for illicit activities and market manipulation remains a significant risk that requires continuous vigilance and adaptation of regulatory measures. The Impact of Hybrid Warfare on the Ongoing Domestic Political Processes in Georgia The National Bank of Georgia for Financial Stability Georgia Crypto License & VASP Registration Support The Impact of Hybrid Warfare on the Ongoing Domestic Political Processes in Georgia
sanctions 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.
sandbox 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 Needs a License: Entities proposing innovative financial services or products under NGB supervision may apply through the Regulatory Laboratory. Activities Requiring Licensing: Testing of new payment systems, blockchain-based solutions, and other fintech innovations. Capital Requirements: No explicit capital thresholds mentioned for sandbox participants; however, systemic risk considerations imply substantial backing is implied. Application Process & Timeline: Applicants must submit a detailed proposal to the Innovations Office; no specific timeline is provided beyond “real-world testing” currently underway. Structural Requirements: Projects must demonstrate compliance with NGB supervisory requirements and pose no systemic risks. Licensed Entities: No cryptocurrency-specific licenses have been issued as of 2025–2026, but sandbox projects are progressing.
securities 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.
stablecoin 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.
status Cryptocurrency is legal in Georgia, but virtual asset service providers (VASPs) are not currently subject to a dedicated licensing regime. The National Bank of Georgia (NBG) serves as the primary financial regulator and has issued public warnings against unregistered virtual asset service providers. No entity has been granted a virtual asset license because no such licensing framework exists; instead, the NBG has explicitly urged citizens not to engage with unregistered virtual asset service providers. The practical reality is that the legal framework for capital markets and securities regulation exists, but virtual assets remain largely outside formal regulatory scope as of 2025–2026. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities The NBG regulates securities markets under the Law of Georgia on Securities Market, which establishes the framework for public offerings, brokerage activities, and securities registrars. Regulatory Framework The Law of Georgia on Investment Funds, the Law of Georgia on Mortgage Covered Bonds, and the Law of Georgia on Securitization constitute the core capital markets legislation administered by the NBG. Regulatory Framework The NBG has issued Order N178/04 regarding recognized foreign stock exchanges and public offerings of securities by international financial institutions in Georgia. Regulatory Framework Order N33/04 of the President of the NBG, dated February 20, 2018, approves the Rules for Recognition of Financial Instruments Trading Systems as an Organized Market. Regulatory Framework Order N145/04 of the President of the NBG approves the rule of licensing and regulating of a brokerage company. Regulatory Framework Decree N167/04 of September 22, 2020, of the Governor of the NBG approves the Rule on Licensing, Registration, Recognition and Regulation of an Asset Management Company. Regulatory Framework Decree N170/04 of September 22, 2020, of the Governor of the NBG approves the Rule on Authorization, Registration, Recognition and Regulation of an Investment Fund. Regulatory Framework
tax 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. Legal form formation (LLC or JSC). Physical office in Georgia with lease agreement. Resident director and responsible officer (physically present ≥14 days/month).
travel rule 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.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-21. View full profile