Crypto-Friendly Georgia: Legal Insights on VASP Licensing and Blockchain Business Setup

Georgia has no restrictive crypto laws, allowing flexible structuring of your blockchain-based business. Georgia’s fintech-friendly banks allow corporate accounts for crypto-related companies. With Georgia’s strategic location and trade agreements, your crypto project can scale globally. 

A Virtual Asset Service Provider (VASP) is a person who provides virtual asset services for the benefit of another person.

The following activities are considered to be virtual asset services:

  • Exchange (including via kiosks) between convertible virtual assets and fiat currencies (national or foreign), between one or more forms of virtual assets, between convertible virtual assets and financial instruments;
  • Transfer of convertible virtual asset;
  • Safekeeping and/or administration of a convertible virtual asset or of the instrument enabling control over a virtual asset;
  • Portfolio management of convertible virtual assets (excluding collective portfolio management);
  • Administration of the trading platform of the convertible virtual assets;
  • Lending of convertible virtual asset;
  • Initial Coin Offering of convertible virtual asset and/or service related to initial coin offering.

A virtual asset is a digital representation of value that is interchangeable and non-unique, can be digitally traded or transferred, and can be used for investments and/or payment purposes. A virtual asset does not include a digital representation of fiat currencies, securities, or other financial instruments.

A convertible virtual asset is a virtual asset that has an equivalent value on the market, in national or foreign currency, in another virtual asset, and/or a financial instrument in which it can be exchanged.

The rules for registration and licensing of virtual asset service providers are defined by the Order N94/04 of the President of the National Bank of Georgia, dated June 13, 2023.

The interested person, in order to register as a Virtual Asset Service Provider (VASP), must submit specific information and documentation to the National Bank of Georgia.

In short, the main requirements include:

  • Completed application form and list of planned services;
  • Information about administrators and beneficial owners;
  • Educational and professional background of responsible persons;
  • Business plan and 3-year financial forecast;
  • Criminal record certificates from all countries of residence;
  • Information about websites and mobile applications used for service delivery;
  • Internal AML/CTF policy (anti-money laundering and counter-terrorism financing);
  • Documents proving ownership or lease of office and branch premises, and evidence of surveillance systems if cash operations are involved.

These are the core registration requirements, while the detailed list is provided in the Law of Georgia and the National Bank’s regulation on the registration of Virtual Asset Service Providers.

Submission Format

The documents provided in accordance with this rule must be presented in the original form or notarised copies. Documents issued in a foreign country must also be authenticated by an Apostille and/or be legalized (unless otherwise defined by legislation). In addition, documents submitted should be a certified translation into the Georgian language.

Terms

The National Bank of Georgia must issue a decision on registration or refusal within 60 calendar days after submission of all required documentation.

This period may be extended twice, by 60 calendar days each time, with prior written notice to the applicant.

If documents are found to be incomplete or defective, the National Bank may give the applicant 30 calendar days to correct the deficiencies.

The National Bank keeps an electronic registry of VASPs and updates it within 2 business days after registration approval.

Registration fee

The state fee for registering a virtual asset service provider is 5,000 GEL.

Other Mandatory Procedures

Beyond specific AML and KYC checks, the regulatory environment in Georgia mandates several other compliance functions:

  • Implementing a formal internal compliance system, which includes appointing a dedicated compliance officer, screening employees, providing ongoing staff training, and conducting independent audits;
  • Keeping detailed records of all identification data, transaction information, and compliance reports for at least five years after a business relationship ends;
  • Adhering to all financial sanctions, such as asset freezes, mandated by United Nations Security Council Resolutions;
  • Maintaining strict confidentiality and refraining from “tipping off” customers that their transactions are being reported or investigated. 

Benefits

From cryptocurrency, you get:

  • Cheap, fast currency exchange with USDT stablecoins, pegged to the dollar at 1:1 and convenient for expats and freelancers who live in Georgia but earn in dollars or euros;
  • An instant, almost commission-free alternative to SWIFT that is very cheap because the banks are kept out of it.
  • Asset diversification, spreading risks, and reducing dependence on traditional currencies and banks;
  • Financial flexibility as interest in digital money and blockchain technologies grows worldwide. You might recall how Donald Trump promised to turn the US into the world’s crypto capital and even formed a strategic crypto reserve (similar to the gold and foreign currency reserve)

Fintech business in Georgia

According to the World Bank’s Global Findex 2021, transaction account ownership in Georgia has doubled over the past decade, reaching 70.5 per cent in 2021. Additionally, nearly 62 per cent of the adult population has engaged in digital payments. However, challenges such as low financial literacy and limited access to financial products, including savings accounts, persist, particularly among poorer households and micro businesses, especially in rural areas.

Estimates range, but around 50 fintechs are operating in Georgia. Beyond fintech, Georgia, along with Armenia, has seen fast growth in its financial services infrastructure. 

In 2021, the National Bank of Georgia (NBG) was exploring the potential launch of a Central Bank Digital Currency (CBDC) as part of efforts to enhance the efficiency of the payment system and further promote financial inclusion.

In Conclusion

Georgia stands out as one of the most progressive and crypto-friendly jurisdictions in the region. With its open legal environment, fintech-supportive banking sector, and fast-growing digital economy, the country offers an ideal setting for blockchain startups and Virtual Asset Service Providers (VASPs).

The licensing process is transparent and well-structured under the National Bank of Georgia’s 2023 regulation, ensuring that legitimate projects can operate confidently within a clear legal framework. Once registered, VASPs benefit from Georgia’s strategic geographic position, liberal tax system, and expanding network of trade and investment agreements, which together enable access to global markets.

As the fintech sector continues to evolve – with digital payments, MPOS, and blockchain technologies expanding rapidly – Georgia is emerging as a bridge between traditional finance and the digital asset economy. For entrepreneurs, investors, and innovators, the message is clear: Georgia is open for crypto business. For reliable legal support, our team is ready to assist you with expertise and professionalism.

 

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Lika Tsintsabadze

Founder of NOMOS Law Firm/Business Lawyer/Attorney at law lika@nomosgeorgia.com