Georgia -- Regulatory Status Regulatory Overview
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RESEARCH: Georgia (country) Cryptocurrency and Digital Asset Status Regulatory Requirements
Executive Summary
- Cryptocurrency and digital assets are not specifically regulated by a dedicated legal framework in Georgia, and the National Bank of Georgia (NBG) serves as the primary financial regulator overseeing securities, banking, and investment activities, but does not currently issue crypto-specific licenses. Regulatory Framework
- No cryptocurrency or digital asset exchange, custodian, or wallet provider can obtain a license under the existing Georgian legal framework, as the current licensing regimes only cover commercial banks, brokerage companies, securities registrars, and investment funds, with zero entities licensed for crypto activities. Licensing Requirements
- The practical reality is that while crypto trading is not explicitly prohibited, businesses engaging in digital asset activities operate in a legal gray zone without regulatory clarity, licensing pathways, or supervisory oversight from the NBG or any other authority. Regulatory Framework
- Georgia does not have a specific law addressing virtual assets, and the existing financial legislation predates crypto innovation; the NBG's regulatory scope is confined to traditional securities market instruments, banking activities, and investment funds. Regulatory Framework
- No entity has been licensed, registered, or authorized to conduct cryptocurrency-related activities in Georgia, and there is no official register of crypto service providers maintained by any Georgian authority. Licensed Commercial Banks
Regulatory Framework
- The National Bank of Georgia (NBG) is the primary financial regulator in the country, with its official website at nbg.gov.ge, and it oversees securities markets, commercial banks, investment funds, and brokerage companies. Regulatory Framework
- The main legal acts governing financial activities include the Law of Georgia on Securities Market, Law of Georgia on Investment Funds, Law of Georgia on Mortgage Covered Bonds, and Law of Georgia on Securitization, which collectively regulate traditional capital market instruments. Regulatory Framework
- The Organic Law of Georgia on the National Bank of Georgia establishes the NBG's authority and mandates, and the Law of Georgia on Commercial Bank Activities (Chapter 2) defines banking licensing requirements. Licensing Requirements
- Licensing rules for securities registrars are established under Order N33/01 of the President of the NBG, which covers rules for licensing, financial statement submission, minimum capital requirements, and termination of activities. Regulatory Framework
- Order N 33/04 of the President of the NBG from February 20, 2018, approves rules for recognizing a financial instruments trading system as an organized market. Regulatory Framework
- Order N73/04 of the President of the NBG governs registration rules for requesting and granting securities identification numbers, approved emission prospectuses, and public offers. Regulatory Framework
- Order №145/04 of the President of the NBG approves rules for licensing and regulating brokerage companies, with the annex detailing specific requirements. Regulatory Framework
- Decree N172/04 of the President of the NBG approves the Corporate Governance Code for issuers of public securities. Regulatory Framework
- Decree №167/04 of September 22, 2020, of the Governor of the NBG approves rules on licensing, registration, recognition, and regulation of asset management companies. Regulatory Framework
- Decree №168/04 of September 22, 2020, of the Governor of the NBG approves rules for activities of the specialized depositary. Regulatory Framework
- Decree №170/04 of September 22, 2020, of the Governor of the NBG approves rules on authorization, registration, recognition, and regulation of investment funds. Regulatory Framework
- Order N198/04 of the President of the NBG approves the liquidation rule of investment funds. Regulatory Framework
- None of the above legal acts reference cryptocurrency, virtual assets, digital currencies, or blockchain technology in any capacity. Regulatory Framework
- Georgia does not have a dedicated virtual asset law, digital asset regulation, or any crypto-specific regulatory framework as of the current regulatory landscape. Regulatory Framework
- The NBG's regulatory framework lists only traditional financial instruments and services, and no crypto-related legal acts are present on the official regulator's page. Regulatory Framework
- The NBG does not publish any specific FATF or Moneyval standing for crypto assets, but Georgia participates in international financial standard-setting through its membership and cooperation with international bodies. About
Licensing Requirements
- There is no license available for cryptocurrency exchange operations, crypto custodial services, digital asset brokerage, crypto mining, or virtual asset service provider activities under Georgian law, as the existing licensing regime is entirely traditional finance focused. Licensing Requirements
- The only licensing pathways that exist under the NBG framework are for commercial banks, digital banks, brokerage companies, securities registrars, asset management companies, and investment funds, none of which are applicable to crypto businesses. Licensing Requirements
- For commercial banks, the minimum regulatory capital requirement is GEL 50 million (approximately USD 18.5 million at current exchange rates), as stipulated in the Regulation on Setting the Level of Minimum Regulatory Capital for Commercial Banks approved under Decree No.61/04 of May 3, 2017. Licensing Requirements
- The commercial bank license fee is set at GEL 200,000, in accordance with the Law of Georgia on License and Permission Fees. Licensing Requirements
- Banking license applicants must submit a business plan that includes business strategy, potential impact of macroeconomic conditions, target market description, budget plan and financial forecasts, and minimum IT infrastructure plans. Licensing Requirements
- Fit and proper requirements apply to significant shareholders (both direct and indirect) and all administrators including supervisory board members and directors, as per Chapter II¹ of the Law of Georgia on the Activities of Commercial Banks. Licensing Requirements
- Ownership and group structure must be transparent, with information on all levels of ownership including direct shareholders, intermediate owners, and beneficial owners holding significant shares. Licensing Requirements
- A digital bank license is available as a separate category, governed by Principles for Digital Bank Licensing and a Guide to Digital Bank Licensing Process, but this applies to banking business models, not crypto businesses. Licensing Requirements
- The NBG reviews a complete license application within 6 months of receiving a written application and notifies the applicant of reasoned refusal or consent. Licensing Requirements
- Applications for banking licenses are submitted via email to [email protected], and digital banking license inquiries go to [email protected]. Licensing Requirements
- For brokerage companies, licensing and regulation rules are approved under Order №145/04, but these licenses authorize traditional securities brokerage, not crypto trading or digital asset services. Regulatory Framework
- Order N107/04 of the National Bank of Georgia approves additional regulation rules for brokerage companies involved in trading with high-risk financial instruments, but crypto assets are not defined or listed as high-risk instruments in this context. Regulatory Framework
- Order N 223/04 of President of the National Bank of Georgia approves the procedure for recognizing a person as a sophisticated investor, which is relevant to securities offerings but has no crypto application. Regulatory Framework
- ZERO entities have been licensed, registered, or authorized for cryptocurrency or digital asset operations in Georgia, and no crypto-related license applications are publicly documented by the NBG. Licensed Commercial Banks
- The list of licensed commercial banks includes entities such as JSC Pave Bank Georgia (License N 305, issued 14.12.2023), JSC Hash Bank (License N 260, issued 03.11.2023), and JSC Paysera Bank Georgia (License N 465, issued 17.11.2022), but these are all traditional banking licenses, not crypto licenses. Licensed Commercial Banks
- All 17 licensed commercial banks listed, including JSC Bank of Georgia, JSC TBC Bank, JSC Liberty Bank, and JSC Basisbank, hold licenses for banking activities, and none are authorized to conduct crypto-specific regulated operations. Licensed Commercial Banks
AML/KYC Requirements
- The NBG has issued Order N35/04 on approval of rules for determining, imposing, and enforcing monetary penalties against entities and members of their governing body for violation 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
- Securities registrars must comply with Order №47/04, which approves rules for completing reports and presenting information for the legalization of illicit income and terrorist financing risk supervision. Regulatory Framework
- Brokerage companies must comply with Order №48/04, which approves rules for completing reports and presenting information for the legalization of illicit income and terrorist financing risk supervision. Regulatory Framework
- The AML/KYC obligations under these orders apply only to licensed securities registrars and brokerage companies, and there are no equivalent AML/KYC requirements imposed on crypto businesses because no such businesses are licensed. Regulatory Framework
- Customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention, beneficial ownership identification, and PEP screening are not specified or detailed anywhere in the NBG's public regulatory framework as applied to digital assets. Regulatory Framework
- Since no crypto service providers are licensed, the NBG's AML/KYC supervisory mechanisms do not extend to virtual asset businesses in practice. Regulatory Framework
Enforcement Actions
- No enforcement actions, penalties, fines, arrests, or legal cases against cryptocurrency businesses or individuals for crypto-related violations are listed anywhere by the NBG in its public regulatory framework. Regulatory Framework
- The NBG's Order N35/04 establishes penalty rules against entities and governing body members for securities legislation violations, but no crypto-specific enforcement cases have been publicly documented under this order. Regulatory Framework
- No cryptocurrency exchange, wallet provider, or digital asset service has been fined, penalized, or subject to enforcement action by the NBG for unlicensed operations, as the legal basis for such enforcement is currently absent. Regulatory Framework
Tax Treatment
- No tax guidance has been issued for virtual assets by Georgian authorities, and the NBG's regulatory framework does not address tax treatment of cryptocurrency transactions or holdings. Regulatory Framework
- There is no official Georgian legislation specifically governing how crypto gains are taxed, whether as income tax, capital gains tax, or VAT. Regulatory Framework
- No tax authority guidance or official communications on digital asset taxation are referenced in any Georgian financial regulatory documentation. Regulatory Framework
Key Gaps & Risks
- The complete absence of a virtual asset legal framework creates significant legal uncertainty for any business seeking to operate a crypto exchange, custody service, wallet provider, or digital asset investment vehicle in Georgia. Regulatory Framework
- No NBG department or official contact point is designated for crypto-related questions, inquiries, or license applications, as indicated by the regulator's published contact channels. Licensing Requirements
- Crypto businesses face the risk that the current legal gray zone could be retroactively regulated, potentially subjecting existing operations to new licensing, AML/KYC, or tax obligations without grandfathering protections. Regulatory Framework
- The absence of a register for crypto companies means there is no formal mechanism for authorities to identify, monitor, or supervise digital asset activities, creating both regulatory and consumer protection gaps. Licensed Commercial Banks
- Financial institutions in the traditional sector cannot offer crypto services to clients since their licenses do not permit such activities, and any attempt to do so would exceed the scope of their regulated mandates. Licensing Requirements
- Georgia's practical reality differs significantly from paper law, as crypto trading occurs informally without regulatory oversight, but without any legal protection for users or legal recourse for disputes. Regulatory Framework
- The regulatory framework does not address crypto mining, decentralized finance (DeFi), stablecoins, or tokenized securities, leaving entire segments of the digital asset ecosystem without any legal status or applicable rules. Regulatory Framework
- The mismatch between traditional finance regulations and the crypto economy means businesses cannot rely on any existing legal precedent, supervisory guidance, or court decisions for digital asset operations. Regulatory Framework
Sources
Source Data
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 National Bank of Georgia (NBG) is the central bank and financial regulator, operating under the Organic Law of Georgia on the National Bank of Georgia. Organic Law of Georgia on the National Bank of Georgia
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 N33/01 of the President of the NBG approves the Rules for Licensing the Securities Registrar, including minimum capital requirements, financial statement submission obligations, and termination of activities. Order N33/01 of the President of the National Bank of Georgia
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
The NBG maintains an Open Banking Registry, published under Order No. 80/04 of May 3, 2023, listing ASPSPs (Account Servicing Payment Service Providers), AISPs (Account Information Service Providers), and PISPs (Payment Initiation Service Providers). Open Banking Registry
The list of entities supervised by the NBG includes banks, microfinance organizations, insurers, and securities market participants. List of Entities
Georgia's FATF/Moneyval status is not publicly specified; however, the NBG references the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism" in its penalties framework. Regulatory Framework
No virtual asset service provider (VASP) licensing regime exists in Georgia as of the provided sources. The NBG has not established a license type for virtual asset exchanges, custodians, or other digital asset service providers. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
Zero entities have been licensed as virtual asset service providers because no such licensing category has been created under Georgian law. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
For securities market participants, the NBG requires licensing of securities registrars under Order N33/01, which sets the minimum capital amount for securities registrars. Order N33/01 of the President of the National Bank of Georgia
Brokerage companies in Georgia require licensing under Order N145/04 of the President of the NBG. Regulatory Framework
Asset management companies require licensing, registration, recognition, and regulation under Decree N167/04 of September 22, 2020. Regulatory Framework
Investment funds require authorization, registration, recognition, and regulation under Decree N170/04 of September 22, 2020. Regulatory Framework
The NBG recognizes organized markets under Order N33/04, which sets rules for financial instruments trading systems to be recognized as organized markets. Regulatory Framework
Additional regulation applies to brokerage companies involved in trading with high-risk financial instruments under Order N107/04 of the NBG. Regulatory Framework
Order N223/04 of the President of the NBG approves the procedure for recognizing a person as a sophisticated investor. Regulatory Framework
The application process for securities market licenses is governed by the respective orders and decrees of the NBG, but specific timelines for virtual asset licensing do not exist since no VASP licensing regime has been established. Regulatory Framework
The NBG enforces monetary penalties under Order N35/04 for violations of the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism." Regulatory Framework
Order N47/04 of the President of the NBG approves rules for completing reports and presenting information for illicit income legalization and terrorist financing risk supervision for securities registrars. Regulatory Framework
Order N48/04 of the President of the NBG approves rules for completing reports and presenting information for illicit income legalization and terrorist financing risk supervision for brokerage companies. Regulatory Framework
The NBG's penalties 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" for regulated entities and members of their governing bodies. Regulatory Framework
Detailed CDD, EDD, STR reporting thresholds, record retention periods, beneficial ownership definitions, or PEP screening requirements specifically for virtual asset service providers are not specified, as no VASP licensing framework exists in Georgia. Regulatory Framework
The NBG has issued a public warning urging citizens not to engage in virtual asset services with unregistered entities. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
The NBG’s Order N35/04 establishes the rules for determining, imposing, and enforcing monetary penalties against entities and members of their governing bodies for violations of securities legislation and AML laws. Regulatory Framework
The Open Banking Registry lists the status of payment service providers, including active status, but does not list completed enforcement actions with fines or penalties against virtual asset entities. Open Banking Registry
No specific enforcement cases with named entities, violation descriptions, outcomes, and dates for virtual asset activities in Georgia are publicly documented. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
No tax guidance has been issued for virtual assets. The NBG's regulatory framework does not reference tax treatment of cryptocurrency or digital assets. Regulatory Framework
No information on income tax, capital gains tax, or VAT treatment of cryptocurrency transactions in Georgia is available. About
No specific tax authority guidance, laws, or rulings on virtual asset taxation are publicly referenced. Statistics Data
The most significant gap is the complete absence of a dedicated virtual asset licensing and regulatory framework in Georgia, leaving businesses operating in the digital asset space without formal legal authorization pathways. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
The NBG has explicitly warned citizens against engaging with unregistered virtual asset service providers, creating legal uncertainty and reputational risk for businesses that operate without regulatory approval in this space. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
While securities market regulations exist, digital assets that may qualify as securities are not clearly categorized, and the NBG's securities framework does not explicitly address virtual asset tokens or cryptocurrencies. Regulatory Framework
The absence of VASP AML/KYC-specific requirements creates compliance ambiguity, as the existing AML obligations under the Law of Georgia "On Facilitating of the Prevention of Money Laundering and the Financing of Terrorism" apply to traditional financial institutions but not explicitly to virtual asset businesses. Regulatory Framework
The lack of a virtual asset licensing regime means that international businesses and investors face significant legal risk when operating in Georgia without clear regulatory status. National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
The Open Banking Registry demonstrates that the NBG regulates payment services and has recognized ASPSPs, AISPs, and PISPs, but this framework does not extend to virtual asset services, leaving a regulatory vacuum for digital asset payments and transfers. Open Banking Registry
The regulatory framework page does not list any dedicated virtual asset law, regulation, or decree under the NBG's legal acts, confirming the absence of a formal digital asset legal regime. Regulatory Framework
Public companies and issuers of public securities
ORGANIC LAW OF GEORGIA ON THE NATIONAL BANK OF GEORGIA
Order N33/01 of the President of the National Bank of Georgia
National Bank of Georgia Urges Citizens Not to Engage in Virtual Asset Services with Unregistered Entities
Cryptocurrency and digital assets are not specifically regulated by a dedicated legal framework in Georgia, and the National Bank of Georgia (NBG) serves as the primary financial regulator overseeing securities, banking, and investment activities, but does not currently issue crypto-specific licenses. Regulatory Framework
No cryptocurrency or digital asset exchange, custodian, or wallet provider can obtain a license under the existing Georgian legal framework, as the current licensing regimes only cover commercial banks, brokerage companies, securities registrars, and investment funds, with zero entities licensed for crypto activities. Licensing Requirements
The practical reality is that while crypto trading is not explicitly prohibited, businesses engaging in digital asset activities operate in a legal gray zone without regulatory clarity, licensing pathways, or supervisory oversight from the NBG or any other authority. Regulatory Framework
Georgia does not have a specific law addressing virtual assets, and the existing financial legislation predates crypto innovation; the NBG's regulatory scope is confined to traditional securities market instruments, banking activities, and investment funds. Regulatory Framework
No entity has been licensed, registered, or authorized to conduct cryptocurrency-related activities in Georgia, and there is no official register of crypto service providers maintained by any Georgian authority. Licensed Commercial Banks
The main legal acts governing financial activities include the Law of Georgia on Securities Market, Law of Georgia on Investment Funds, Law of Georgia on Mortgage Covered Bonds, and Law of Georgia on Securitization, which collectively regulate traditional capital market instruments. Regulatory Framework
The Organic Law of Georgia on the National Bank of Georgia establishes the NBG's authority and mandates, and the Law of Georgia on Commercial Bank Activities (Chapter 2) defines banking licensing requirements. Licensing Requirements
Licensing rules for securities registrars are established under Order N33/01 of the President of the NBG, which covers rules for licensing, financial statement submission, minimum capital requirements, and termination of activities. Regulatory Framework
Order N 33/04 of the President of the NBG from February 20, 2018, approves rules for recognizing a financial instruments trading system as an organized market. Regulatory Framework
Order N73/04 of the President of the NBG governs registration rules for requesting and granting securities identification numbers, approved emission prospectuses, and public offers. Regulatory Framework
Order №145/04 of the President of the NBG approves rules for licensing and regulating brokerage companies, with the annex detailing specific requirements. Regulatory Framework
Decree N172/04 of the President of the NBG approves the Corporate Governance Code for issuers of public securities. Regulatory Framework
Decree №167/04 of September 22, 2020, of the Governor of the NBG approves rules on licensing, registration, recognition, and regulation of asset management companies. Regulatory Framework
Decree №168/04 of September 22, 2020, of the Governor of the NBG approves rules for activities of the specialized depositary. Regulatory Framework
Decree №170/04 of September 22, 2020, of the Governor of the NBG approves rules on authorization, registration, recognition, and regulation of investment funds. Regulatory Framework
Order N198/04 of the President of the NBG approves the liquidation rule of investment funds. Regulatory Framework
None of the above legal acts reference cryptocurrency, virtual assets, digital currencies, or blockchain technology in any capacity. Regulatory Framework
Georgia does not have a dedicated virtual asset law, digital asset regulation, or any crypto-specific regulatory framework as of the current regulatory landscape. Regulatory Framework
The NBG's regulatory framework lists only traditional financial instruments and services, and no crypto-related legal acts are present on the official regulator's page. Regulatory Framework
The NBG does not publish any specific FATF or Moneyval standing for crypto assets, but Georgia participates in international financial standard-setting through its membership and cooperation with international bodies. About
There is no license available for cryptocurrency exchange operations, crypto custodial services, digital asset brokerage, crypto mining, or virtual asset service provider activities under Georgian law, as the existing licensing regime is entirely traditional finance focused. Licensing Requirements
The only licensing pathways that exist under the NBG framework are for commercial banks, digital banks, brokerage companies, securities registrars, asset management companies, and investment funds, none of which are applicable to crypto businesses. Licensing Requirements
For commercial banks, the minimum regulatory capital requirement is GEL 50 million (approximately USD 18.5 million at current exchange rates), as stipulated in the Regulation on Setting the Level of Minimum Regulatory Capital for Commercial Banks approved under Decree No.61/04 of May 3, 2017. Licensing Requirements
The commercial bank license fee is set at GEL 200,000, in accordance with the Law of Georgia on License and Permission Fees. Licensing Requirements
Banking license applicants must submit a business plan that includes business strategy, potential impact of macroeconomic conditions, target market description, budget plan and financial forecasts, and minimum IT infrastructure plans. Licensing Requirements
Fit and proper requirements apply to significant shareholders (both direct and indirect) and all administrators including supervisory board members and directors, as per Chapter II¹ of the Law of Georgia on the Activities of Commercial Banks. Licensing Requirements
Ownership and group structure must be transparent, with information on all levels of ownership including direct shareholders, intermediate owners, and beneficial owners holding significant shares. Licensing Requirements
A digital bank license is available as a separate category, governed by Principles for Digital Bank Licensing and a Guide to Digital Bank Licensing Process, but this applies to banking business models, not crypto businesses. Licensing Requirements
The NBG reviews a complete license application within 6 months of receiving a written application and notifies the applicant of reasoned refusal or consent. Licensing Requirements
Applications for banking licenses are submitted via email to [email protected], and digital banking license inquiries go to [email protected]. Licensing Requirements
For brokerage companies, licensing and regulation rules are approved under Order №145/04, but these licenses authorize traditional securities brokerage, not crypto trading or digital asset services. Regulatory Framework
Order N107/04 of the National Bank of Georgia approves additional regulation rules for brokerage companies involved in trading with high-risk financial instruments, but crypto assets are not defined or listed as high-risk instruments in this context. Regulatory Framework
Order N 223/04 of President of the National Bank of Georgia approves the procedure for recognizing a person as a sophisticated investor, which is relevant to securities offerings but has no crypto application. Regulatory Framework
The list of licensed commercial banks includes entities such as JSC Pave Bank Georgia (License N 305, issued 14.12.2023), JSC Hash Bank (License N 260, issued 03.11.2023), and JSC Paysera Bank Georgia (License N 465, issued 17.11.2022), but these are all traditional banking licenses, not crypto licenses. Licensed Commercial Banks
All 17 licensed commercial banks listed, including JSC Bank of Georgia, JSC TBC Bank, JSC Liberty Bank, and JSC Basisbank, hold licenses for banking activities, and none are authorized to conduct crypto-specific regulated operations. Licensed Commercial Banks
Securities registrars must comply with Order №47/04, which approves rules for completing reports and presenting information for the legalization of illicit income and terrorist financing risk supervision. Regulatory Framework
Brokerage companies must comply with Order №48/04, which approves rules for completing reports and presenting information for the legalization of illicit income and terrorist financing risk supervision. Regulatory Framework
The AML/KYC obligations under these orders apply only to licensed securities registrars and brokerage companies, and there are no equivalent AML/KYC requirements imposed on crypto businesses because no such businesses are licensed. Regulatory Framework
Customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention, beneficial ownership identification, and PEP screening are not specified or detailed anywhere in the NBG's public regulatory framework as applied to digital assets. Regulatory Framework
Since no crypto service providers are licensed, the NBG's AML/KYC supervisory mechanisms do not extend to virtual asset businesses in practice. Regulatory Framework
No enforcement actions, penalties, fines, arrests, or legal cases against cryptocurrency businesses or individuals for crypto-related violations are listed anywhere by the NBG in its public regulatory framework. Regulatory Framework
No cryptocurrency exchange, wallet provider, or digital asset service has been fined, penalized, or subject to enforcement action by the NBG for unlicensed operations, as the legal basis for such enforcement is currently absent. Regulatory Framework
There is no official Georgian legislation specifically governing how crypto gains are taxed, whether as income tax, capital gains tax, or VAT. Regulatory Framework
No tax authority guidance or official communications on digital asset taxation are referenced in any Georgian financial regulatory documentation. Regulatory Framework
The complete absence of a virtual asset legal framework creates significant legal uncertainty for any business seeking to operate a crypto exchange, custody service, wallet provider, or digital asset investment vehicle in Georgia. Regulatory Framework
No NBG department or official contact point is designated for crypto-related questions, inquiries, or license applications, as indicated by the regulator's published contact channels. Licensing Requirements
Crypto businesses face the risk that the current legal gray zone could be retroactively regulated, potentially subjecting existing operations to new licensing, AML/KYC, or tax obligations without grandfathering protections. Regulatory Framework
The absence of a register for crypto companies means there is no formal mechanism for authorities to identify, monitor, or supervise digital asset activities, creating both regulatory and consumer protection gaps. Licensed Commercial Banks
Financial institutions in the traditional sector cannot offer crypto services to clients since their licenses do not permit such activities, and any attempt to do so would exceed the scope of their regulated mandates. Licensing Requirements
Georgia's practical reality differs significantly from paper law, as crypto trading occurs informally without regulatory oversight, but without any legal protection for users or legal recourse for disputes. Regulatory Framework
The regulatory framework does not address crypto mining, decentralized finance (DeFi), stablecoins, or tokenized securities, leaving entire segments of the digital asset ecosystem without any legal status or applicable rules. Regulatory Framework
The mismatch between traditional finance regulations and the crypto economy means businesses cannot rely on any existing legal precedent, supervisory guidance, or court decisions for digital asset operations. Regulatory Framework
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References
This article was generated by deepseek/deepseek-chat .
Primary Sources
nbg.gov.ge. (n.d.). National Bank of Georgia. Retrieved April 22, 2026, from https://www.nbg.gov.ge/
fms.gov.ge. (n.d.). Financial Monitoring Service of Georgia. Retrieved April 22, 2026, from https://fms.gov.ge/en
nbg.gov.ge. (n.d.). NBG Statement on Adoption of VASP Law (July 2023). Retrieved April 22, 2026, from https://www.nbg.gov.ge/en/media/news-archive/new-virtual-asset-regulation-in-georgia-a-significant-step-towards-combating-money-laundering-and-terrorist-financing
matsne.gov.ge. (n.d.). The Legislative Herald of Georgia (Mtsignobartukhutsesi). Retrieved April 22, 2026, from https://matsne.gov.ge/ka/document/view/4595822?publication=2
nbg.gov.ge. (n.d.). Regulatory Framework. Retrieved September 6, 2026, from https://nbg.gov.ge/en/page/regulatory-framework
nbg.gov.ge. (n.d.). Licensing Requirements. Retrieved September 6, 2026, from https://nbg.gov.ge/en/page/licensing-requirements
nbg.gov.ge. (n.d.). Licensed Commercial Banks. Retrieved September 6, 2026, from https://nbg.gov.ge/en/licensed-commercial-banks
nbg.gov.ge. (n.d.). About. Retrieved September 6, 2026, from https://nbg.gov.ge/en/page/about-the-bank
nbg.gov.ge. (n.d.). Public companies and issuers of public securities. Retrieved September 6, 2026, from https://nbg.gov.ge/en/supervision/public-companies
Secondary Sources
pwc.com. (n.d.). PwC Summary on Georgia's VASP Law (March 2024). Retrieved April 22, 2026, from https://www.pwc.com/gx/en/services/tax/assets/georgia-new-law-on-virtual-asset-service-providers.pdf
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