Our crypto and blockchain lawyers in Tbilisi advise on Georgian VASP registration, stablecoin approvals, AML compliance, token projects and disputes. We help founders establish the legal requirements before launch and support existing providers with their ongoing obligations.
A Georgian company registration is only the first step for a crypto business. Before accepting customers, the founders need to establish which services require National Bank of Georgia (NBG) registration, how much capital the business must maintain and who will be responsible for compliance. Our lawyers help turn that assessment into the application, contracts and operating documents the business needs.
A Virtual Asset Service Provider, or VASP, provides virtual asset services for another person. Regulated activities include:
We start with the proposed customer transactions, asset flows and custody arrangements. A project's description as a software platform, broker, DeFi product or token issuer does not settle its legal classification. Holding or trading the company's own assets also needs to be distinguished from providing services to customers.
The process commonly called a VASP licence in Georgia is registration with the NBG. It is separate from incorporating an LLC. The registration identifies the permitted services. We check the NBG consent and notification requirements before an existing provider adds another service. See the NBG's VASP information and register.
The August 2026 amendments introduced minimum supervisory capital according to the services provided. Stablecoin issuers have a separate requirement.
| Activity | Minimum capital |
|---|---|
| Exchange and/or transfer services | GEL 150,000 |
| Other virtual asset services, excluding stablecoin initial offerings | GEL 250,000 |
| Administration of a virtual asset trading platform | GEL 350,000 |
| Stablecoin issuer under the dedicated initial-offering rules | GEL 500,000 |
For multiple services under the general VASP capital rule, the highest applicable minimum applies. These amounts are supervisory capital, rather than registration charges or legal fees. Capital eligibility and continued compliance also matter.
Providers registered before 27 August 2026 have until 1 July 2027 to meet the new risk-management requirements and 1 September 2027 to meet the general capital requirements. The amending order also excludes relevant administrative proceedings started before it took effect. We check the registration and application dates before advising on the applicable requirements.
Sources: Order No. 207/04 of 26 August 2026, Articles 1 and 2; stablecoin rules, Article 5.
A new stablecoin initial offering requires VASP registration and the NBG's prior written consent. Incorporation or general VASP registration alone is insufficient.
The dedicated rules cover issuer governance, capital, reserve assets, redemption rights, the offering document, audit and reporting. Reserve backing must remain at least 100% of the value of stable virtual assets in circulation, with capital and reserves kept separate.
The September 2026 amendment defines a stable virtual asset by reference to a peg to the Georgian lari or another fiat currency and introduces reserve-placement and concentration limits. A token linked to another type of asset needs its own legal assessment. Existing issuers must also check the applicable transitional provisions.
We review the proposed token and holder rights, prepare the legal documents and coordinate the application with the financial, audit and technology specialists involved.
Sources: Order No. 52/04 of 6 March 2026 and Order No. 214/04, effective 10 September 2026.
We prepare and review customer and beneficial-owner checks, business risk assessments, sanctions screening, transaction monitoring, escalation procedures, suspicious-activity reporting and record retention. These documents need to reflect the customers, countries, assets and transactions the business actually handles.
The 2026 VASP rules also address operational and cyber risks, technology resilience, fraud, business continuity and security testing. We work with the company's compliance and technology teams to document responsibilities, outsourcing arrangements and responses to incidents.
For virtual asset transfers, we assess the information that must accompany transactions, how it will be exchanged securely and the applicable implementation dates. Travel Rule planning belongs in the product and operating procedures as well as the AML policy.
Sources: 2026 VASP risk-management and monitoring amendments; virtual-asset transfer information rules. Related reading: Georgia's AML framework.
Our work includes Georgian company formation, ownership and director documents, shareholder agreements and the corporate material needed for an NBG application. We also assist with bank onboarding documents, while the bank makes its own acceptance decision.
For tokenisation and smart-contract projects, we examine the rights promised to holders, the flow of funds and the responsibilities of each participant. A token representing securities or another financial instrument may fall under a different regulatory regime. Collective investment, payment services and customer funds need separate attention.
We draft and review platform terms, custody and wallet agreements, token-sale documents, technology and outsourcing contracts, risk disclosures and dispute provisions. Legal review is coordinated with technical review where the code or custody system needs specialist examination.
We advise on failed transfers, exchange and custody disputes, shareholder conflicts, fraud allegations and regulatory investigations. The first task is to preserve the transaction records and identify the parties, relevant country and available legal remedies.
Keep transaction hashes, wallet addresses, platform statements, contracts and correspondence. These records can help establish what happened, although an on-chain transfer alone does not prove who controlled a wallet. We assess evidence preservation, urgent court applications, civil claims and criminal-law issues according to the facts. Recovery cannot be promised.
We work in English, Georgian and Russian. Initial advice and document preparation can often be handled remotely. Where a power of attorney or foreign corporate documents are needed, we confirm the certification, apostille or legalisation and Georgian translation requirements for the issuing country.
Send us a short description of the planned services, customer countries, custody model, shareholders and proposed management. If the business is already operating, include its NBG registration details and any regulatory correspondence. We can then identify the work required and provide a written fee proposal.
No. Incorporating a company does not replace NBG VASP registration. The proposed exchange services, capital, management, compliance systems and operating arrangements must be assessed before launch.
The general minimums are GEL 150,000 for exchange and/or transfer, GEL 250,000 for other covered services and GEL 350,000 for trading-platform administration. Stablecoin issuers have a separate GEL 500,000 minimum. The service combination, capital eligibility and transitional provisions must also be checked.
No. The VASP definition concerns services for another person. Trading your own assets must be distinguished from handling customer trades, transfers or custody. We assess the actual transactions rather than relying on the business's description.
Georgian rules generally prohibit direct virtual-asset payments, subject to specific NBG exceptions connected with virtual asset services. VASP registration does not itself authorise ordinary merchant payments. A proposed crypto-to-fiat settlement arrangement needs a separate legal assessment.
Yes. Foreign founders can establish a Georgian company. A regulated crypto business must separately meet NBG requirements, and the founders' other countries of operation may impose additional obligations. Parts of the preparation can be handled remotely through properly documented representation.
The original acts and their amending orders should be read together. Georgian-language legal texts govern where an English translation has not yet been updated.
For a new application, an existing provider's compliance review or a crypto dispute, contact our legal team or use the form below. You can also read about VASP registration in Georgia and meet our advocates and attorneys.
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