It’s not precise enough to describe a legal application like “We’re creating our own cryptocurrency platform”.
Customers can convert cryptocurrency to fiat? Does the platform permit virtual assets to be transferred? Will the company control client wallets and private keys? Do they manage a lending platform for digital assets and issuing tokens, or overseeing a trading system?
Those differences matter when pursuing an crypto license in Georgia due to the services that a company is planning to provide influence its regulatory preparation documents, controls, and capital requirements.
Georgia is a great place for fintech companies, but to be able to access its controlled virtual asset market, you need more than just registering a business and building a website.
First, define the Service.
Based on the model described by PB Services, businesses providing covered services in the field of virtual assets for third parties are required to register as Virtual Asset Service Providers (ASP) with the National Bank of Georgia.
The scope encompasses activities like exchange of virtual assets and transfer, platform administration for trading as well as cryptocurrency custody management. Importantly, according to the regulations provided, the custody concept includes administration of a customer’s private key and wallet.
That makes the technical design of a product in the crypto space relevant to its regulatory position.
An entrepreneur who is interested in obtaining the crypto licence in Georgia should sketch out the customer’s journey before formulating the application. What happens after a customer deposits assets? Who controls the account? Can assets be exchanged, or transferred? Who is the entity that is able to authorize a transaction?
Clarity in the answers helps to understand what the firm is actually doing.
Your business plan must detail the actual business
VASP applications need more than just a visually attractive pitch deck.
According to the information supplied by according to the information provided, National Bank requires a detailed business plan that contains financial projections for the minimum of three years. These include expenses, revenue, and growth projections. The plan must also indicate genuine intent to operate in Georgia.
It is important to address this issue as quickly as you can.
Investors may ask questions such as how quickly the business will grow. A business plan for a regulatory operation must also include details about how the operation will be conducted responsibly.
For companies seeking a vasp license Georgia applicants should be prepared to connect the commercial model with the compliance model rather than treating them as unrelated documents.
AML Does not qualify for inclusion in the End
Anti-Money Laundering and Counter-Terrorism Financing control is one of the major components of the plan provided by PB Services.
The material is specifically cautioned against simply importing a policy regarding AML from another jurisdiction because Georgian laws must be incorporated into the framework of a business.
The operational systems must be considered also. Business plans must show that the company’s systems can spot related and suspicious transactions from the start.
Practically, the quality of a product should influence its development prior to being launched. By building a platform and then deciding on the way AML can be implemented it can lead to unnecessary delays and redesign.
Capital is contingent on the Services You Choose
Determining the business model as early as possible is crucial for a variety of reasons, such as regulatory capital.
Based on the thresholds set in the sources, kiosks and exchange activities require 150 000 GEL. Administration of trading platforms is required to be 350,000 GEL and other services need 250,000 GEL. If there are multiple services offered, the threshold that is most applicable is the one that is.
This is distinct from operating capital or capital investment. A proof that the requested amount is actually paid for must accompany the request. Additionally, the capital has to be maintained throughout operation.
An entrepreneur who is planning to apply for a cryptocurrency blockchain certification in Georgia should therefore think about regulatory capital during financial planning not until the rest of the application has been assembled.
Registration is not the end of the compliance process.
The compliance calendar doesn’t disappear at the moment of approval. The guidelines outline ongoing obligations in cybersecurity and risk management, technology resilience and risk of fraud and record retention, independent review and complaints from customers.
To get an audit-free opinion from an independent source on the framework for risk management companies must register within 12 months. The rules for handling complaints require businesses to accept complaints in written, oral or in electronic format and to evaluate them within a time limit of a month, and send complaint statistics electronically to the National Bank each month.
These factors affect the way serious applicants should approach licensing.
Imagine that you are using a Georgian VASP Application as the style of a regulated business.
A company’s structure, business model and technology, AML controls as well regulatory capital, risk procedures and customer service processes have to be consistent.
Georgia continues to provide opportunities for crypto and fintech companies, and its regulation framework gives businesses a clearly defined path to market. The best place to begin is not to ask what speed a license is going to be granted.
It’s being able, specifically, to detail what your crypto company intends to accomplish and prove that your company will be operating in accordance with the legal framework of Georgia.