Why Georgia is a serious choice for crypto licensing
You definitely need a license
The National Bank of Georgia introduced new regulations – effective July 1, 2023 – as part of the fight against money laundering.
Previously, any organization could buy, sell, exchange, or store cryptocurrency for the benefit of a third party. It is now illegal for anyone not registered as a virtual asset service provider (VASP). Fail to comply with licensing requirements, and you may find yourself staring down the barrel of cool GEL 20,000 fine.
Cryptocurrency is still a great business opportunity
That has not stopped Georgia’s cryptocurrency market from being a great business opportunity.
It is easy to open a company in the country, lenient tax legislation is suited to rapid growth, and demand for VASP services is virtually guaranteed: Tbilisi ranks first worldwide in terms of the number of crypto-mats for every USD 10 billion of GDP. And that with only 2.39% of the population owning virtual assets – a fraction of a percent less than Hong Kong, Italy, and Australia, and twice as much as in neighboring Armenia and Azerbaijan
Why Georgia?
Georgia has made a deliberate effort to become a financial and fintech hub for the region — and the institution leading that effort is the National Bank of Georgia.
The National Bank is among the most professional and accessible financial regulators in the Caucasus. Their staff understand the technology, engage seriously with applicants, and are actively working to attract legitimate financial companies to the country. What sets them apart is their Financial Technology Laboratory — a sandbox environment where companies with new ideas can test concepts in a controlled setting and work directly with regulators to shape an appropriate legal framework.
Since the VASP framework came into effect in 2023, 37 licenses have been issued — including to large international exchanges such as Bybit and WhiteBIT, which obtained Georgian licenses as part of their global compliance strategies, as well as to local Georgian companies and new market entrants. The demand is real. The framework is functional. And the National Bank is committed to making it work.
highlights
Who can obtain VASP status
Company director
The director should have a degree in economics or a related field or experience in financial services or virtual assets
Physical presence
At least one of the company’s authorized representatives must be in Georgia for at least 14 days in a calendar month
management
The company and its management must be squeaky clean
LLCs and JSCs
Benefits
Services you can provide with a crypto license
Virtual asset exchange
Cryptocurrency transfer
Custody and management of cryptocurrency assets or portfolios
Crypto lending
Initial Coin Offering (ICO)
Step by step requirements
How to get a crypto license in Georgia
To obtain a VASP license in Georgia, your application needs to address four distinct areas.
Think of these as four separate blocks, each requiring careful preparation. Weakness in any one of them can delay or derail your application.
Legal documents
The National Bank requires a standard set of legal and identity documents: notarized passports, criminal background checks, credit history, corporate structure documents, and proof of company registration.
If you are not based in Georgia, many of these documents will need to come from your home country, and each has its own validity period — so timing matters. An experienced lawyer can manage this block efficiently. The key is systematic organization: build your checklist early, gather everything in order, and package it correctly before submission.
Business plan and financial projections
The National Bank wants a detailed business plan — including financial projections for at least three years: revenue forecasts, expense modeling, growth assumptions. More importantly: your business plan must demonstrate a genuine intention to operate in Georgia.
Your international client base is not a problem — there is no rule requiring all revenue to come from Georgian clients. But Georgia must be the center of your operation.
AML and CFT policy
Every licensed financial entity in Georgia is required to maintain a comprehensive internal policy document covering Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT). The National Bank holds applicants to a high standard, this document is how they assess whether your company is serious about compliance.
The most common mistake: assuming that an AML policy from another jurisdiction — another country, another license — can be translated into Georgian and submitted. It cannot. Georgian AML and CFT legislation has specific requirements, and your internal policy must reflect those requirements precisely,
This document must be built from scratch, with a thorough understanding of Georgian law, and it is where the National Bank will focus most of their scrutiny. Plan for it in advance and specialist input.
Source of funds and source of wealth
If your business plan states that you need, say, one million dollars to launch and grow your business, you must demonstrate that you actually have access to that capital — and that it comes from a documented, legitimate source.
“I sold a property several years ago and received cash” is not sufficient. The National Bank needs to trace the chain of funds clearly and completely. Every link in that chain must be documented.
This has real practical implications: think carefully about who will be the founder or beneficial owner of the company, and whether that person can provide clear, documented evidence of the origin of their funds. If there are gaps in the paper trail, plan to resolve them before submitting — not after.
How long does the VASP licensing process take?
Preparation
Gathering legal documents, writing the business plan and financial projections, and building yourAML/CFT policy from the ground up takes approximately one to one and a half months if you approach it seriously and have the right team. This is not a phase to rush — the strength of your preparation determines how smoothly the rest of the process goes.
NBG initial review
Once you submit, the National Bank has 60 days to respond. That response will almost certainly come as a list of remarks and questions — not an approval or a rejection. This is standard procedure. It is not a bad sign.
The list of remarks might have 10 items. It might have 50. Some will be minor — a word choice, a formatting issue, a missing signature. Others may require substantive revisions to
your documents. The National Bank is thorough and detailed, which is ultimately a good thing.
Your response window
When you receive the remarks list, you have one month to respond and resubmit. That month goes quickly. Address each point systematically and move efficiently — do not spend three weeks deliberating and then rush the final submission.
Extended review
After your resubmission, the National Bank is legally permitted to extend their review by an additional 60 days. Given the current volume of applications, plan for them to use the full time available.
Total realistic timeline
State fee per submission: GEL 5,000 (approximately USD 1,800). This fee applies to each submission, including resubmissions. The National Bank cannot refuse an application without stating a specific reason — and you can address that reason and reapply
immediately, with no mandatory waiting period.
Get in touch
How we helped GeCrypto become a registered VASP in Tbilisi
registration framework, PB Services handled the full process: from company structure
review and AML/CFT policy preparation to NBG submission and follow-up. The exchange
received its registration and began operating within the regulated framework.
