Georgian Crypto License

Local Company (LLC or JSC)

The applicant for the VASP license must be a Georgia-registered entity. LLCs are common; they require at least one director and one shareholder (they can be foreigners, and the same person can be both). No minimum capital is mandated for LLCs (even 1 GEL capital is acceptable) . For JSCs, a minimum 100,000 GEL capital applies (25% paid initially) – JSCs might be chosen if the company plans to issue shares or tokens akin to securities. The company’s scope of business must include virtual asset services – this means listing the relevant NACE (industry activity code) for crypto services when registering the company.

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Fit and Proper Management

All directors, shareholders, and ultimate beneficiaries must have an impeccable reputation (no criminal convictions, especially financial crimes) . Georgian authorities require a criminal record check from the home country of foreign directors, usually recent (within 3 months) and apostilled if not in Georgian. Key persons should ideally have some relevant experience in finance or IT – while not strictly required by law, it strengthens the application. There is no requirement to have a Georgian citizen as a director or shareholder; 100% foreign ownership is allowed and common. Likewise, local residency for directors is not mandatory – Georgia permits non-resident management, which is a big draw for foreign founders . (Do note: While foreign management is allowed, one must still ensure effective communication with regulators; having at least one Georgian point of contact or proxy can be helpful.)

 

AML/KYC Obligations

Georgian VASPs are treated as “Obliged Entities” under Georgian AML law. This entails rigorous KYC on customers (collecting full name, ID/passport info, verifying identity, obtaining proof of address for higher risk customers, etc.), and recording all crypto transactions with identifying info. If transactions appear suspicious or exceed certain thresholds, VASPs must file reports to the Financial Monitoring Service (FMS) of Georgia. The company is expected to use tools to monitor crypto transactions for illicit activity (e.g., screening wallet addresses against sanctions or blacklists) . An internal AML policy document is required, describing how the firm complies with customer due diligence, enhanced due diligence for high-risk customers, ongoing monitoring, and record retention.

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Local Presence (Minimal)

A significant benefit in Georgia is that there is no strict local office or staffing requirement. You are not required to hire local employees or maintain an operating office space by law . Many crypto companies can operate from abroad while registered in Georgia. However, you do need a registered address (often provided by a local agent or lawyer) for the company. Also, while not mandatory, having a local representative (even a lawyer) who can liaise with NBG can be practical. There is no residency requirement for the AML Compliance Officer either – but that person must be readily contactable and able to file reports to FMS.

 

Capital Requirements

Georgia does not impose a specific minimum capital for VASPs aside from the standard corporate formation rules . In practice, having some capital or operational funds is expected; the NBG may ask for a bank statement or audit to prove the company’s financial soundness. Most importantly, if the business model involves holding client funds or pre-funding liquidity, the NBG will want assurance that the company has sufficient capital or reserves to protect clients. But compared to EU jurisdictions, Georgia’s financial requirements are very light.

 

Application Fee and Licensing Fee

The state fee for the crypto license (registration) is ~1500 GEL as of recent info . Thereafter, the license does not have a heavy annual fee. However, minor fees may apply for notarizations, translations (all submitted documents not in Georgian must be accompanied by a Georgian translation), and for obtaining any required legalizations.

 

Scope of Allowed Activities

With the VASP registration, the company is authorized to engage in a wide range of crypto activities including: exchanging crypto and fiat, crypto-to-crypto exchange, operation of a crypto trading platform (exchange), custodial wallet services, crypto transfer services, administering ICOs/token offerings, and even crypto lending . Georgia’s law outlines these permitted services broadly, giving licensed companies flexibility. Important: If the company plans to do an ICO or similar token sale, additional disclosures might be required to NBG (especially if advertising to the public).

 

Timeline and Transition

After submission, expect roughly 1–2 months for approval . Georgia’s NBG aims to be efficient, but if documents are missing or need clarification, it can pause the clock. The registration is valid indefinitely as long as compliance is maintained; there’s no need for annual renewal of the license itself (though the company must renew its business registration annually like all companies, which is a simple admin filing). With MiCA coming in the EU, Georgian companies might find it easier to partner or do business with EU firms because Georgia’s standards are designed to be comparable (e.g., KYC, Travel Rule adherence). This equivalence with EU norms is touted as a benefit for Georgian VASPs operating internationally.