Georgia VASP Licensing Eligibility Checker
This tool helps determine if your crypto business needs a Georgia VASP license and assesses your compliance requirements. Based on the latest Georgia banking regulations (O.C.G.A. § 7-1-681(b)) and NBG guidelines.
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Ever wondered why a handful of crypto startups are pulling out of Georgia while others are setting up shop? The answer lies in a tightly woven set of banking restrictions that dictate who can move digital money and how they must stay on the right side of the law.
What the rules actually say
Georgia is a Eurasian country that, in the past few years, has positioned itself as a crypto‑friendly destination while still demanding strict compliance from financial players.
The National Bank of Georgia (NBG) acts as the chief regulator for all crypto‑related activities. Since July12023, the NBG has enforced the Virtual Asset Service Provider (VASP) registration law a licensing regime that applies to every entity offering crypto services. Miss the paperwork and you’ll quickly find yourself on a cease‑and‑desist list.
Who needs a license?
Under O.C.G.A. §7‑1‑681(b), any person who transmits money or monetary value-including cryptocurrency a digital asset that can be transferred without a traditional bank-must hold a money transmitter license a state‑granted authorization to move funds on behalf of others or fall under a narrow exemption (O.C.G.A. §7‑1‑682).
The Georgia Department of Banking and Finance the enforcement arm that monitors compliance, issues licenses, and pursues violations has issued several high‑profile orders in 2025. On January16, 2025, both Bullet Blockchain, Inc. and RocketBTM (Blockchain Technology Machines, Inc.) were shut down for operating Bitcoin ATMs without the required license.
Licensing checklist - what you need to prepare
| Requirement | What the regulator expects | Typical exemption |
|---|---|---|
| Beneficial‑owner disclosure | Full names, passport data, ownership % for each stakeholder | Purely custodial services with no transfer function |
| Capital adequacy | Minimum 250,000GEL liquid capital | Small‑scale kiosk operators handling under 5,000GEL/month |
| AML/CFT controls | Real‑time transaction monitoring, SAR filing within 24hrs | Peer‑to‑peer wallets with no fiat on‑ramp |
| Technology audit | Independent security audit report (ISO27001 or equivalent) | Manual, offline cash‑based vending machines |
Tax landscape - sweet deals and hard lines
Georgia’s tax code is a mix of incentives and realities. Individuals enjoy a 0% tax on crypto transactions, which is a big draw for traders and everyday users. Companies, however, pay a 15% corporate tax on distributed profits. The policy aims to keep the ecosystem vibrant while still feeding the national treasury.
Current figures (2025) show the government holding 66BTC (about$6.86million) and projecting a 14.13% adoption rate - roughly 153,000 users - worth $1.9million in market revenue. Those numbers illustrate how the tax structure fuels growth without creating a fiscal vacuum.
Compliance in practice - AML/CFT is non‑negotiable
The Financial Monitoring Service (FMS) Georgia’s unit that reviews suspicious‑activity reports and enforces AML/CFT rules works hand‑in‑hand with the NBG. Every licensed VASP must embed KYC checks at onboarding, run continuous transaction screening, and submit SARs (Suspicious Activity Reports) within 24hours of detection.
Failure to comply can trigger immediate revocation of the license, hefty fines, or even criminal prosecution. The 2025 cease‑and‑desist orders demonstrated that the Department will not hesitate to act.
International alignment - why the IMF matters
In March2024, the International Monetary Fund (IMF) praised Georgia’s AML/CFT upgrades, noting they match global standards. This endorsement not only reassures foreign investors but also paves the way for future cross‑border digital‑asset projects.
Looking ahead, Georgia plans to fully embed digital assets into its AML/CFT framework by 2026. The roadmap includes tighter reporting thresholds, expanded cooperation with foreign regulators, and a sandbox for emerging tokenized services.
Practical steps for businesses eyeing Georgia
1. **Assess whether you fall under an exemption** - If you only host a non‑transfer wallet, you may avoid the money‑transmitter license.
- Check O.C.G.A. §7‑1‑682 details.
2. **Compile the licensing dossier** - Gather shareholder IDs, financial statements, AML policy drafts, and a recent security audit.
3. **Submit to the Georgia Department of Banking and Finance** - Expect a 60‑day review period; be ready to answer follow‑up questions from Rod Carnes, Deputy Commissioner for Non‑Depository Financial Institutions.
4. **Build a compliant KYC/KYB workflow** - Use reputable identity‑verification providers and integrate real‑time transaction monitoring.
5. **Plan for ongoing reporting** - Set up automated SAR generation and keep audit logs for at least five years.
Following this checklist dramatically reduces the risk of being the next bullet‑point on a cease‑and‑desist list.
Common pitfalls and how to dodge them
Missing the capital requirement - Many start‑ups think a small cash reserve is enough. The law is blunt: you need the full 250,000GEL unless you qualify for a kiosk exemption.
Weak AML policies - A generic “we’ll follow the law” statement won’t cut it. The FMS expects documented procedures, employee training logs, and a clear escalation path.
Assuming crypto is legal tender - Georgia treats crypto as a tradable asset, not a currency. This nuance matters when drafting contracts and pricing models.
Future outlook - what’s next after 2026?
Beyond the full AML/CFT integration, the NBG is scouting for ways to bring tokenized securities, stablecoins, and CBDC pilots under its umbrella. For businesses, this signals a need to stay agile: today’s compliant VASP might need to upgrade its tech stack in two years to handle centralized stablecoin reporting.
Meanwhile, the low‑cost energy environment continues to attract miners, and the 0% individual tax keeps retail participation high. Expect the adoption curve to steepen, especially as educational campaigns roll out across Tbilisi’s universities.
Frequently Asked Questions
Do I need a money‑transmitter license to run a crypto wallet app in Georgia?
Only if the app allows users to transfer funds to third‑party wallets or fiat accounts. Purely custodial wallets that never move value out of the app can qualify for the exemption under O.C.G.A. §7‑1‑682.
What is the corporate tax rate for crypto‑related profits?
Georgia applies a flat 15% corporate tax on distributed profits for crypto businesses. Undistributed earnings are taxed at the standard corporate rate of 10%.
How long does the VASP licensing process take?
The NBG typically reviews applications within 60 days, but complex cases involving extensive AML/CFT systems can stretch to 90 days.
Are there any tax benefits for individual crypto traders?
Yes - individuals face 0% tax on crypto‑to‑crypto, crypto‑to‑fiat, and fiat‑to‑crypto trades, making Georgia one of the most tax‑friendly jurisdictions for retail traders.
What happens if I operate an ATM without a license?
The Department of Banking and Finance can issue an immediate cease‑and‑desist order, impose fines up to 100,000GEL, and refer the case for criminal prosecution.
Comments
8 Comments
Teagan Beck
Thanks for the deep dive, really helpful.
That licensing checklist makes the process feel less daunting.
Good luck to anyone navigating the Georgian rules.
Kim Evans
The overview does a solid job of breaking down the VASP licensing maze in Georgia.
I appreciate the clear distinction between full‑service exchanges and pure custodial wallets.
It’s also useful to see the exact capital reserve threshold of 250,000 GEL spelled out in plain terms.
The tax section, highlighting 0 % for individuals and 15 % corporate tax, gives a realistic picture of the fiscal landscape.
The step‑by‑step checklist for assembling a licensing dossier feels like a cheat‑sheet for founders.
I especially like the tip about checking O.C.G.A. § 7‑1‑682 for possible exemptions before you waste resources.
The inclusion of real‑world examples, like the Bullet Blockchain shutdown, drives the point home that compliance is non‑negotiable.
The AML/CFT requirements, such as real‑time monitoring and 24‑hour SAR filing, are demanding but sensible.
Knowing that the IMF has praised Georgia’s upgrades adds a layer of credibility for foreign investors.
The roadmap toward 2026, with tighter reporting thresholds and a sandbox for tokenized services, shows the regulator’s forward‑thinking attitude.
For crypto miners, the note about low‑cost energy and the continued 0 % individual tax is a compelling draw.
The FAQ section neatly answers the most common doubts without cluttering the main article.
Overall, the piece balances legal detail with practical advice, making it a valuable reference.
If you’re plotting to set up a VASP in Tbilisi, start by mapping your service type against the exemption matrix.
And don’t forget to keep audit logs for at least five years, as the regulator expects diligent record‑keeping. 😊
Steve Cabe
If you think Georgia is some tax haven you can exploit without consequence, you’re dangerously naive. The law is explicit: any entity moving crypto value must obtain a money‑transmitter license unless it qualifies for a narrow exemption. Ignoring the 250 000 GEL capital requirement is not a minor oversight; it’s a direct violation of O.C.G.A. § 7‑1‑681(b). The recent crackdown on unlicensed Bitcoin ATMs proves the authorities will enforce this rigorously. So plan your compliance strategy carefully, or face swift legal action.
shirley morales
While the guide is thorough it reeks of over‑optimism about Georgia’s regulatory friendliness. The tone suggests anyone can sidestep the heavy compliance burden with a few forms – a notion far from the harsh reality. Regulatory bodies are not lenient; they enforce capital and AML rules rigorously. One must respect the gravity of these obligations.
Mandy Hawks
Reading through the licensing requirements feels like peering into the evolving contract between technology and state. The balance between fostering innovation and safeguarding financial integrity is delicate, and Georgia appears to be testing that equilibrium. It raises questions about how much flexibility a jurisdiction should grant before compromising oversight. Ultimately, the ecosystem thrives when clarity and fairness coexist.
Scott G
Indeed, the discourse surrounding regulatory equilibrium warrants a measured approach. The Georgian framework, by delineating explicit capital and AML mandates, strives to provide such equilibrium. Entities seeking licensure would benefit from a thorough review of both statutory provisions and prevailing enforcement trends. A diligent compliance posture not only satisfies legal obligations but also enhances institutional credibility.
VEL MURUGAN
Look, the article nails the key compliance points but skips a crucial risk factor – the volatility of the local fiat market. Capital held in GEL can erode quickly, undermining the 250 000 GEL reserve threshold in practice. Also, the piece glosses over the operational costs of maintaining ISO‑27001 audits, which can be prohibitive for startups. Ignoring these financial stressors could lead to premature licensing failures.
Russel Sayson
The Georgia VASP regime is a masterclass in regulatory ambition, and it's worth dissecting each layer. First, the clear capital floor of a quarter‑million GEL ensures that only serious players enter the market, filtering out fly‑by‑night operators. Second, the AML/CFT obligations, especially the 24‑hour SAR filing, demand real‑time monitoring systems that many nascent firms simply cannot afford without significant investment. Third, the exemption carve‑outs for pure custodial wallets create a nuanced sandbox where innovation can flourish without the full licensing burden – a brilliant compromise if executed correctly. Fourth, the tax structure, with zero individual tax, dramatically lowers the entry barrier for retail traders, potentially swelling user adoption numbers. Fifth, the alignment with IMF standards boosts international credibility, making Georgia an attractive hub for cross‑border projects. Sixth, the upcoming 2026 roadmap signals that the regulator is not static; it will tighten thresholds and expand oversight, meaning today's compliance strategy must be future‑proof. Seventh, the enforcement actions against Bullet Blockchain and RocketBTM serve as stark reminders that non‑compliance is met with swift, decisive action. Eighth, the requirement for ISO‑27001 audits is not merely a formality – it forces firms to adopt industry‑grade security postures. Ninth, the detailed licensing dossier checklist reduces ambiguity, offering a clear roadmap for applicants. Tenth, the provision for five‑year audit log retention ensures that regulators have a long‑term view of operational conduct. Eleventh, the practical steps outlined – from gathering shareholder IDs to automating SARs – provide a tangible implementation plan. Twelfth, the overall ecosystem benefits from this structured approach, balancing innovation with robust consumer protection. 🚀
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