The regulatory application shouldn’t include the statement “We are creating a cryptocurrency platform”.
Customers can convert cryptocurrency to fiat? Will the platform allow virtual assets to be transferred? Is the company in charge of client wallets or keys? Does it manage the trading platform, lending against digital assets, or planning to issue tokens?

Those differences matter when pursuing cryptocurrency licenses in Georgia due to the services that a company is planning to provide will impact its preparation for regulatory compliance as well as documentation, controls and capital requirements.
Georgia offers a regulated market for virtual assets, which is attractive to fintech companies. However, gaining access to this market takes more effort than simply registering your company and launching your website.
First, Define the Service
Businesses offering virtual assets services to third parties under the framework described in PB Services must register with the National Bank of Georgia as Virtual Asset Service Providers.
This includes virtual-asset transfer and exchange, management of trading platforms, as well as the management or custody of cryptocurrency. Importantly, according to the regulations provided the concept of custody encompasses the administration of a client’s private keys and wallet.
The technical design of the product in question is pertinent to its place in terms of regulation.
A founder interested in obtaining a crypto license in Georgia should therefore map the proposed customer journey before preparing the application. What happens when a user makes a deposit of funds? Who manages your wallet? Assets can they be exchanged or transferred? Who is the one who approves the transaction?
Clear answers help establish what the firm will be doing.
Your Business Plan Needs to provide a realistic description of your business
VASP applications require more than a stunning pitch deck.
According to the provided information According to the information provided, the National Bank expects a detailed business plan, which includes projections of financials covering at least three years, including costs, revenues, and growth expectations. The plan must also demonstrate a real intent to operate within Georgia.
It is essential to deal with this issue as quickly as possible.
A business plan written for investors will answer questions like how fast the business can expand. The business plan for a regulatory operation must also contain details on how it will be run safely.
For companies seeking a vasp license Georgia applicants must be able to connect the commercial model to the compliance model instead of considering them separate documents.
AML is not able to be added at the end
The Anti-Money Laundering as well as the Counter-Terrorism Controls for financing are one of the major components of the plan provided by PB Services.
The document specifically states that just importing an AML policy from a different jurisdiction is not sufficient since Georgian regulations must be integrated into the company’s structure.
The operational systems are important also. The business plan needs to demonstrate that the company’s systems can identify related and potentially suspicious transactions from the start.
Practically, the quality of a product should influence the development of the product before it can be released. The process of creating a platform before looking into how AML procedures fit in the future could lead to unnecessary changes and cause delays.
The Services You Select Can Change Your Capital
The need to establish the business model in time is a result of the capital required by the regulatory authorities.
According to the thresholds in the materials used for the source, kiosks as well as exchange activities are required to be 150 000 GEL. Management of trading platforms requires 350,000 GEL while other covered services are only required to be 250,000 GEL. When multiple services are provided the threshold that is the most applicable determines.
It’s not the same as normal operating capital. Evidence that the required amount is actually financed must be included with the application and the capital must be kept in place throughout the operation.
The founder who plans to obtain a an authorization for crypto-blockchain in Georgia should therefore think about regulatory capital when planning financial plans and not once the rest the application has already been made.
Registration isn’t the end of compliance process.
The compliance calendar doesn’t disappear when the calendar is approved. approval. The provided requirements outline continuous obligations pertaining to risk management, cybersecurity technology, fraud risk, recording retention, independent review and complaints from customers.
In order to receive an independent audit opinion on the risk management framework A company must sign up within 12 months. The rules state that companies are required to take complaints written or verbally and examine them within a month. They also have to send statistics of complaints to the National Bank electronically each month.
These particulars affect the manner serious applicants should take the licensing process.
Imagine an Georgian VASP Application as the design of an unregulated business.
It is important that the organization’s structure, technology, AML controls and regulatory capital, as well as customer processes, are in harmony.
Georgia has opportunities for businesses in the field of fintech and crypto and the regulatory framework offers a straightforward path to the market. But the most effective starting point isn’t determining how quickly an approval can be obtained.
It is essential to explain in detail how your crypto-business is planning to do and show that you’re prepared to comply with Georgia’s regulations.
