Is Crypto Legal in Georgia?

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 National Bank of Georgia (NBG) is the primary financial regulator in Georgia, operating under the Organic Law of Georgia on the National Bank of Georgia, and serves as the supervisory authority for multiple categories of financial institutions including virtual asset service providers The National Bank of Georgia and AML / CFT Supervision.

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.

The National Bank of Georgia is authorized under the Law of Georgia "On Facilitating the Prevention of Money Laundering and the Financing of Terrorism" to supervise virtual asset service providers (VASPs), which implies that VASPs must be registered with and authorized by NBG to operate legally in Georgia 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.

The National Bank of Georgia supervises VASPs for AML/CFT compliance, which means VASPs must implement customer due diligence (CDD) measures, enhanced due diligence (EDD) for high-risk customers, and ongoing transaction monitoring in accordance with the AML/CFT Law and NBG supervisory expectations AML / CFT Supervision.

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

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.

Law of Georgia on Virtual Assets (LoVA), Article 3: Defines "Virtual Asset," "Virtual Asset Service Provider," and references the classification consistent with MiCA.

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.

Law of Georgia on Virtual Assets (LoVA), which empowers the National Bank of Georgia to issue detailed secondary legislation and regulations regarding reserve requirements for specific categories of virtual assets, especially those backed by fiat or other assets. (The general principles are embedded in the LoVA, with granular rules to follow from NBG).

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.

Law of Georgia on Virtual Assets (LoVA), Chapter II, Article 7 onwards: Outlines the licensing requirements for Virtual Asset Service Providers, which includes issuers of 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.

Law of Georgia on Virtual Assets (LoVA) implicitly supports redemption rights through its alignment with MiCA, which mandates such rights. Specifics will be detailed in NBG secondary legislation.

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.

The Law of Georgia on Investment Funds and the Law of Georgia on Mortgage Covered Bonds and the Law of Georgia on Securitization also form part of the securities regulatory architecture under NBG's supervision Regulatory Framework.

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