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