Common reasons Georgian banks refuse to open accounts for foreign nationals and how to eliminate the risk

The Georgian banking system is one of the most developed in the world. In 2024, Global Finance recognized BoG, TBC, and Liberty as Central and Eastern Europe’s best banks for corporate clients, with BoG similarily taking top spot in the individual rating. The good news is that there are no legal restrictions on non-residents opening an account in Georgia or taking out a mortgage or loan. The bad news is the bank sometimes says “no”.

Banking regulations in Georgia

Georgian banks adhere to global standards for combating money laundering and terrorist financing, the so-called AML/CFT policies developed by the international Financial Action Task Force (FATF). Local anti-corruption and sanctions control regulations and recommendations of the National Bank of Georgia also exist, in addition to the internal regulations in place in the banks themselves.

The result is a rather complex and intricate compliance system that, although generally looking to assess potential legal, financial, and reputational risks, can differ significantly from bank to bank. 

At the end of the day, the most common difficulties opening an account in a Georgian bank can be attributed to the KYC (Know Your Customer) procedure.

The main reasons for refusing to open an account

Mistakes in the application form

Step one in the KYC procedure is a passport and an application form that can be completed in person at the bank or remotely by e-mail or a form on the bank website. The form usually asks for basic information about the person (name, , address), information about employment, expected turnover for the year, a list of countries and counterparties with which financial transactions will be conducted, the reason for wanting to open the account, and property, among others.

The form is usually in Georgian, which can be a problem if you don’t know the language, and the bank may refuse to open an account if:

• Fields are left blank
• Contradictory information is provided 
• Answers are worded vaguely
• Income doesn’t match bank statements (which the bank may request additionally)
• Addresses are old, contact information provided are not work-related

It’s free to apply at some Georgian banks, but at others there is a processing fee of GEL 50 (roughly USD 20) to be paid immediately at a cash desk or terminal, and the application won’t be processed without confirmation of payment. Banks don’t usually refund the money even if you’re rejected, though you may not have to pay again should you choose to reapply.

Problems confirming source of income

Apart from the application form, some banks seek to verify the legality and transparency of the funds intended for the account as part of the KYC process and may ask for:

• A funds flow statement from a bank where you already have an account. The statement period may vary, though the compliance department tends to look at the last 6-12 months.
• A certificate from your employer about your income and taxes withheld. The form of the certificate differs from country to country (2-NDFL, W-2, P60, etc.). An employment contract or certificate of salary is also an option.
• Agreements of purchase and sale of real estate, gift and inheritance agreements, certificates of winnings (with confirmation of tax payment).
• Documents confirming the ownership of securities, if the income is formed at the expense of interest, dividends, and active trading on the stock exchange.
• Documents of a legal entity, if you are its founder (founding papers, confirmation of dividends, contracts).
• A tax return and other documents.

If you cannot satisfy the bank’s request or provide a satisfactory alternative, it is very likely you will be rejected. But then, even all the documents you could possibly hope for are no guarantee. The compliance department may take issue with fluctuations in income, outdated documents, discrepancies between the information in the questionnaire and certificates, or a lack of official employment.

Are you a risky client?

The bank uses the results of the initial check to categorize a client as low, medium, or high risk in relation to the extent to which their monetary transactions may be related to money laundering, attempts to circumvent official sanctions, or any number of other financial irregularities. The higher the risk level, the more documents the bank will ask for, and the more likely it is to reject you.

Banks don’t generally publish open lists of who exactly they consider high-risk, and they each have their own criteria: You could end up being classified as high risk at one while getting cleared at another. Anyway, practice shows high-risk clients to be:

• Individuals included in sanctions lists and employees of sanctioned companies
• Civil servants and employees of certain state-owned companies
• Political refugees or activists under investigation or embroiled in a political conflict
• Individuals associated with the arms business
• Individuals with a criminal record or bad credit history
• Individuals dealing with cryptocurrencies. Although generally tolerated in Georgia, such transactions can be used to circumvent sanctions, launder proceeds, or finance prohibited activities

Even if this describes you, it doesn’t mean you should immediately give up. Each bank has its own criteria for high-risk clients, and the human factor can play a role: Sometimes a decision is that of a particular employee and not necessarily that of the organization’s policy.

How to protect yourself when opening an account in Georgia

First, make sure you’ve got all the documents you need before you submit your application. 

Second, keep your documents up to date: If you are applying in the middle of 2025, don’t provide the return for 2015.

Third, fill out the application form carefully. If some point is unclear to you, you can always clarify its meaning with a bank employee or somewhere online.

In some countries additional proof of your connection to the country is required, but in Georgia you don’t have to provide a residence permit, work visa, contract with a Georgian company, or local address to open an account, something that makes banks in Georgia especially accessible for non-residents.

Can a bank account be opened by power of attorney?

The short answer is “yes”, in most banks. If you are unable or unwilling to travel to the country, you can delegate the task.

But it is important to remember that opening an account by power of attorney in Georgia does not free you from the need to fill out a questionnaire and disclose the source of your funds, you’re just passing the buck to your representative.

Perhaps it shouldn’t have to be said, but it is important that the power of attorney be drawn up correctly:

• The document must be drawn up in Georgian or translated into it (with the translation certified by a notary)
• The rights of the representative to open an account must be clearly spelled out
• Marks in signatures and inaccuracies in passport data will sink you immediately
• The power of attorney must have a validity period (preferably with a reserve for possible delays)
• The power of attorney itself must be notarized. For some countries, an apostille or consular legalization is also required
• The document must be paper: The bank will not accept a digital copy

So which bank should you open an account with in Georgia?

The largest banks in the country are TBC and Bank of Georgia, but the BoG subsidiary SOLO Bank is also very popular among foreigners. As we wrote at the beginning of the article, they are the most reliable and convenient and have received awards for their digital banking innovations and leadership within Georgia and the Central and Eastern European region. It’s not uncommon to read online about the trials one must endure to open an account here, but in our experience, and we have a fair bit, that isn’t quite fair: if you fill everything out correctly and submit the right documents, the bank approves you. 

Liberty Bank and Basisbank open accounts for non-residents only if the clients plan to move to Georgia. They are in the process of merging, and will be controlled by the Chinese Hualing Group, which is ultimately controlled by the Chinese state.

Credo is generally considered the easiest bank for non-residents to open an account in, with a simpler application procedure and higher percentage of approvals. On the downside, service leaves something to be desired, including for international money transfers.

What to do if a bank rejects you

Just because one bank has refused to open an account for you doesn’t mean you won’t be able to open one elsewhere – there are plenty of fish in the sea. If you’ve been turned down, you can always:

• Apply to another branch of the same bank. Sometimes it comes down to the human factor. Maybe you’ve been rejected because the manager made an error in the documents or the compliance officer was in a bad mood and not because you’re an irredeemable hard case.
• Wait a couple weeks or months and reapply. Practice shows second and third attempts to sometimes bring the desired result, especially if you improve your package of documents during the waiting period.
• Apply to another bank with more flexible requirements. As we wrote above, Credo opens its arms a little wider to foreign nationals than BoG and TBC.
• Seek professional advice. If you don’t understand why you’ve been rejected, it might be time to ask someone with a professional understanding of the banking sector in Georgia to look over your application and find the gaps, be it insufficient documents, mistakes in the application form, or KYC problems.

The lawyers at PB Services are here to help you open a bank or brokerage account in Georgia, and if you are unable to visit the country in person, we have a list of banks that open accounts by power of attorney. Just use the form below to find out more.