The regulatory application should not include the statement “We are in the process of launching a cryptocurrency platform”.
Can users convert cryptocurrency into fiat? Can the platform be used to move virtual assets? The company will have control over wallets for clients and private keys? Are they managing an online trading platform and lending against digital assets or is it planning to issue tokens?
These distinctions matter when applying for a cryptocurrency license to operate in Georgia. The kind of services a business intends to offer influences its preparation for regulatory documents controls, as well as capital requirements.
Georgia is an ideal location for fintech companies, but to enter its regulated virtual asset market is more than registering a company and establishing a website.
First, define the service
Businesses that provide virtual asset services to third party within the framework outlined in PB Services must register with the National Bank of Georgia as Virtual Asset Service Providers.
The scope includes actions like virtual transfer and exchange of assets as well as managing trading platforms and custody management for cryptocurrency. The regulatory information provided states that the concept of custody extends to the management of the clients’ private keys or wallet.
The technical design of a crypto-product relevant to its regulatory status.
Before submitting an application for a license an entrepreneur who is interested in getting an e-currency permit in Georgia must sketch out the customer journey. What happens when the customer deposits their assets? Who is in charge of your wallet? Can assets be traded or transferred? Who can authorise transactions?
The answers that are precise and clear can help decide what the business will be doing.
Your Business Plan Must Describe the Real Business
VASP applications also require more than a pretty pitch deck.
According to the provided information The National Bank expects a detailed business plan with financial projections covering at least three years, which includes revenue, expenses, and growth projections. The plan should also show the genuine intention to do business in Georgia.
This need should be taken seriously and addressed as early as possible.
A business plan written for investors will answer questions like: How quickly can the company grow? A business plan for the regulatory process must include details about how the business will be managed safely.
Companies that are seeking a vasp Georgia license should be prepared to link the commercial model with the compliance model, instead of considering the two documents as distinct documents.
AML cannot be added to the end
PB Services describes the preparation as a series of steps that include anti-money laundering and anti-terrorism financing controls.
The document specifically states that just importing an AML policy from a different jurisdiction is not sufficient since Georgian regulations must be incorporated into the company’s structure.
It is also essential to look at the operational systems. The business plan must prove that the company’s system can recognize potential suspicious transactions as well as related transactions.
Practically speaking, the conformity of a product has to influence its design before it’s released. It is not recommended to create a platform prior to deciding on how AML policies are to be implemented. This could lead to costly redesigns and delays.
The services you choose to use can Impact Your Capital
Capital for regulatory purposes is another reason to determine the business model before.
As per the thresholds set out in the sources, exchange and transfer activities, including kiosks, require 150,000 GEL. The administration of platforms for trading requires 350,000 GEL and other services require 250,000 GEL. If there are multiple services offered the threshold that is highest applies.
This is different from normal operating capital or capital investment. The proof that the amount requested is actually paid for must be included with the request, and the capital must be maintained throughout the duration of operation.
A founder planning to get crypto blockchain license in Georgia should consequently consider regulatory capital during financial planning not after the rest of the application has already been assembled.
Registration Don’t End the Compliance Work
The compliance calendar doesn’t end when you have approval. These requirements cover regular obligations relating to cybersecurity, risk management and technology resilience. They also cover the retention of records, independent review customers’ complaints, record retention.
In order to receive an independent audit opinion on the risk management framework companies must register within twelve months. In accordance with the regulations, companies must take complaints written or verbally and then review them within a month. They also have to transmit statistics about complaints to the National Bank electronically each month.
These particulars can alter the way an experienced license applicant approaches licensing.
Instead of thinking of a Georgian VASP application as a set of documents required for obtaining permission, think of it as the design of an regulated business.
The structure of the company, its service model and technology AML controls, capital regulations processes for risk, as well as customer processes have to connect.
Georgia is a great place to start firms in fintech and crypto, and the regulatory framework gives a clear path into the market. But the strongest starting point isn’t determining how quickly a license can be obtained.
It’s being able, with specificity, describe what your crypto business is planning to do and demonstrate that the company will be operating within the legal framework of Georgia.