In August 2026, “TSQ Investment Group” became a subject of public debate in Georgia — an online scheme that its critics call a financial pyramid. Georgian law does not recognise a “pyramid” as a standalone offence, but that does not mean the scheme sits in a legal vacuum. Below: what is actually documented, which provisions apply, and what a person who has already paid in should do.
Every provision cited here was checked against the consolidated text in the legal.ge legal library: the Criminal Code, the Criminal Procedure Code and the Civil Code as consolidated on 25 June 2026; the Organic Law on the National Bank of Georgia and the Law on the Securities Market as consolidated on 1 April 2026.
I. What we know about TSQ — documented facts only
Before turning to legal qualification, it is essential to separate what is documented from what remains at the level of public statements and media reporting. To date there is no court verdict against TSQ in Georgia, and no publicly known decision bringing charges. The analysis below therefore concerns the described model of the scheme, not an established crime.
- A Spanish regulator’s warning. The National Securities Market Commission (CNMV) added “TSQ INVESTMENT GROUP LTD” to its warning list under the category “unregistered/unlicensed entity offering a financial product or service”. Source: CNMV → IOSCO I-SCAN, alert No. 39835; published 28 July 2025, entered into the IOSCO database on 8 August. Status: an official act of a regulator.
- The National Bank’s warning. The NBG issued a warning about suspected financial pyramids circulating on social media that promote investment in cryptocurrency trading. Source: National Bank of Georgia, 26 August 2026. Status: a public regulator warning — without naming any company.
- The scheme’s estimated size. “The amount Georgians have put into this scheme is roughly USD 30 million”; recruitment runs through closed WhatsApp, Telegram and Facebook groups. Source: economist and former National Bank president Roman Gotsiridze, 30 August 2026. Status: a public statement — an evaluative opinion, not official data.
- Blocked withdrawals. Reports circulated that withdrawals from the platform were delayed or blocked. Source: public warning circulated in Georgian media, 28 August 2026. Status: unverified information — requires checking.
- Domain and operating channels. The domain tsqinvestmentgroup.com was registered on 11 September 2024; operations run through messenger groups; a person known as “Professor Henry” features prominently. Source: international review platforms (Alertopedia, TradersUnion). Status: secondary source — not official.
- The Georgian-language public page. The Facebook page “TSQ Currency Exchange” (roughly 7,100 followers) publishes a daily “signal schedule” and promotional creatives; the page category is listed as “Musician/band”. Source: direct observation of the public page, 1 September 2026. Status: primary and verifiable — but may be deleted at any time.
- Absence of registration. TSQ does not appear in the National Bank’s register of Virtual Asset Service Providers (VASPs). Source: the National Bank’s VASP register. Status: verifiable from the register.
What a “financial pyramid” means in the National Bank’s own definition. According to the NBG, a financial pyramid is a scheme that collects money from the public by promising returns significantly above market rates while, for the most part, making no profitable investment at all — the only source of the promised return is recruiting new participants or extracting further money from existing ones. The indicators the NBG lists include: promises of unrealistic returns; returns that depend on recruiting new members; an opaque investment mechanism; a lack of transparency about financial standing; and aggressive marketing on social media.
What the scheme says about itself — open-source observation
For legal qualification, what matters is not the critics’ assessment but what the scheme itself promises — because the content of that promise is what constitutes the element of deception in fraud. One public Facebook page operating in Georgia under the TSQ name presented the following picture as of 1 September 2026:
- Page name — “TSQ Currency Exchange”, with roughly 7,100 followers; its materials also carry “TSQ Crypto Exchange”, “N1 TSQ INVESTMENT GROUP” and “TSQ INVEST GROUP Georgia”.
- The page’s Facebook category — “Musician/band”. An entity that presents itself as a currency and crypto-asset exchange is classified on the platform as a music page.
- A published “signal schedule” — a daily timetable with fixed slots (15:25, 17:00, 19:25, 21:00, 22:00) under the slogan “Every day · Exact time · More profit”.
- The promotional creatives are built on emotional, collective messaging — “Together we build a successful future!”, “Our team — your path to success!” — rather than on concrete, verifiable financial information.
- Post text is partly corrupted with invisible characters (zero-width characters inserted between letters), a known technique for evading automated moderation and keyword search.
- In the comments — a question posted in late August 2026: “Friends, are you able to withdraw funds from your TSQ platform accounts?”
Each of these observations maps directly onto the indicators listed by the National Bank — an opaque investment mechanism, a lack of transparency about financial standing, and aggressive marketing on social media. Legally, there are three separate questions here: (a) what the entity presents as its source of income, (b) what it does not disclose about its legal entity and licence, and (c) how deliberately it avoids being identified.
This material exists today and may be gone tomorrow. When a scheme collapses, the first things to disappear are precisely the promotional pages, groups and posts. If you are among those affected, archive the promotional creatives and the posts describing the “promised return” today — this is the material that will later help prove the element of deception.
II. The core problem: “pyramid” is not a standalone offence in Georgian criminal law
The Criminal Code of Georgia contains no article titled “financial pyramid” or “organising a pyramid scheme”. This sets Georgia apart from jurisdictions where a pyramid scheme is described as an independent tort or offence.
The practical consequence cuts both ways. On one hand, investigators are forced to fit the scheme into general offences — which raises the evidentiary burden. On the other hand, those general offences are broad enough that, correctly applied, they fully cover the conduct of a pyramid scheme’s organiser. Below are the six lines along which such a scheme meets Georgian law.
1. Fraud — Article 180 of the Criminal Code
This is the central provision. Under paragraph 1 of Article 180, fraud is “the taking of another’s property or the acquisition of a property right by deception, for the purpose of unlawful appropriation”.
In a pyramid scheme, the element of deception usually localises in three facts:
- A lie about the source of income — the participant is told the return comes from trading or investment, when in reality it is covered by the contributions of new participants;
- A lie about risk — a “guaranteed” or fixed percentage promised where the asset is in fact speculative or non-existent;
- A lie about status — presenting oneself as a licensed or regulated financial institution.
The sanction escalates with the qualifying elements. Paragraph 1 — a fine, community service of 170 to 200 hours, corrective labour of up to 2 years, house arrest of 1 to 2 years, or imprisonment of 2 to 4 years. Paragraph 2 (committed by a group acting in prior agreement, or causing significant damage) — a fine or imprisonment of 4 to 7 years. Paragraph 3 (abuse of official position, a large amount, or repeat commission) — a fine or imprisonment of 6 to 9 years. Paragraph 4 (committed by an organised group, or by a person twice or more convicted of misappropriation or extortion) — imprisonment of 7 to 10 years.
The monetary thresholds are set by the note to Article 177, which governs this entire chapter of the Code: a large amount is above GEL 10,000, and significant damage is above GEL 150. Because the note applies chapter-wide, these thresholds bear directly on Article 180. In practice this means damage of just over GEL 150 already falls within paragraph 2; above GEL 10,000 it moves into paragraph 3; and where an organised network is established, into paragraph 4.
A note on terminology. One argument comes up constantly: “but people paid in voluntarily”. Voluntariness does not exclude fraud — the whole point of Article 180 is that the victim hands over the property themselves, but does so on the basis of a will formed under the influence of deception.
2. Virtual asset services without registration
If the scheme operates with crypto-assets — receiving USDT, storing it, exchanging it, or administering a trading platform — a separate, specific prohibition is engaged.
Under Article 52⁵(2) of the Organic Law “on the National Bank of Georgia”, a virtual asset service provider is obliged to register with the National Bank and to satisfy the requirements it sets. Paragraph 3 of the same article states directly: “It is inadmissible for virtual asset services to be provided by a person who is not a virtual asset service provider registered by the National Bank, or a representative of the financial sector authorised to provide virtual asset services under the legislation regulating its activity.”
In addition, Article 39¹ establishes that a virtual asset is not legal tender and that payments with it are prohibited — except in those cases defined by a legal act of the National Bank which are necessary for providing virtual asset services themselves.
This is a practical verification tool: anyone can check the National Bank’s VASP register in under a minute to see whether a given platform is registered. TSQ does not appear in that register.
3. Illegal entrepreneurial activity — Article 192
Article 192 penalises entrepreneurial activity “without registration, permit or licence, or in breach of permit or licence conditions, which has caused significant damage or has been accompanied by the receipt of income in a large amount”. The sanction is a fine, house arrest of 6 months to 2 years, or imprisonment of 1 to 3 years; where committed by a group, repeatedly, or by a person already convicted of such an offence — a fine or imprisonment of 3 to 5 years.
The note to this article is particularly significant: for such conduct, a legal entity is punished by a fine, by deprivation of the right to carry on activity, or by liquidation together with a fine. In other words, if the scheme is served by an LLC or another legal entity registered in Georgia, that entity itself becomes a subject of criminal liability.
4. Public offering of securities, bypassing the regulator
If the scheme offers not merely “trading signals” but the acquisition of a financial instrument or a share, the Law “on the Securities Market” applies. Under paragraph 1 of its Article 3, a public offering is “an offer to no fewer than 100 persons, or to an unspecified number of persons, for the direct or indirect sale of securities on behalf of the issuer”, and such an offering is permissible only where the person submits the information prescribed by that law to the National Bank.
An offer made through closed but mass messenger groups will as a rule far exceed that threshold — “closedness” does not automatically strip an offering of its public character. The only carve-out the law recognises is an offering made exclusively to experienced investors (Article 3(6)) — the direct opposite of mass recruitment on social media.
5. Money laundering — Article 194
If money obtained from the scheme is disguised, converted or moved in order to conceal its origin, Article 194 is engaged — legalisation of illegal income. The base sanction is a fine or imprisonment of 3 to 6 years; committed by a group, repeatedly, or accompanied by income in a large amount — 6 to 9 years; committed by an organised group, through abuse of official position, or accompanied by income in an especially large amount — 9 to 12 years.
Under the note to this article, a large amount is income from GEL 30,000 to GEL 50,000, and an especially large amount is income above GEL 50,000. A legal entity is punished by liquidation or by deprivation of the right to carry on activity, together with a fine.
6. A separate question: the liability of “leaders” and recruiters
The pyramid model rests on the people who bring in acquaintances, relatives and followers in exchange for compensation. Their legal position is frequently misunderstood — as though they were “just giving advice”.
Under paragraph 3 of Article 25 of the Criminal Code, the liability of an organiser, an instigator and an accessory is determined by the relevant article with a reference to Article 25 — that is, by Article 180 itself — except where they were at the same time co-perpetrators of the offence. A co-perpetrator answers directly under Article 180, with no reference to Article 25. Put differently: the deeper a “leader” is involved in running the scheme, the heavier their procedural position becomes, not the lighter.
What decides the matter is culpability: under Article 25(1), a perpetrator and an accomplice bear criminal liability only for their own guilt. That is precisely why continuing to recruit after regulators have issued public warnings is a qualitatively different situation, in terms of proving the subjective element, than recruiting before them.
The dual-role trap. In a pyramid, a person is frequently both a victim and a recruiter at the same time. This is a real risk: collecting “leader” bonuses and actively building a network during a period when the scheme’s problems are already public knowledge changes the legal assessment sharply. If you were in such a role, it is better to consult a lawyer before making any public or legal statements.
III. The civil track: invalidity and recovery of money
Criminal prosecution and getting your money back are not the same thing. Georgian civil law provides independent grounds.
Invalidity of a transaction on grounds of deception. Article 81 of the Civil Code: where a person has been deceived into entering a transaction, they are entitled to demand that it be declared invalid, where it is evident that the transaction would not have been concluded without the deception. Paragraph 2 also covers silence — the concealment of circumstances which, had they been disclosed, would have led the other party not to express their will; though the duty of disclosure exists only where the party could in good faith have expected it. Article 82 clarifies that it is irrelevant whether the deception aimed at obtaining a benefit or at causing harm.
The critical deadline. Article 84: a transaction concluded through deception may be challenged within one year from the moment the person entitled to challenge it learned of the existence of the ground. This is a very short period, and in practice missing it is what costs people their claim.
Recovering the money. Once invalidity is established, Article 976 comes into play — a person who has transferred something to another in performance of an obligation may demand its return where the obligation does not exist because the transaction is invalid or on another ground. Paragraph 2 of the same article separately stresses that the claim for return is excluded once the limitation period has expired — one more reason delay is expensive.
Compensation for damage. An independent ground is Article 992: a person who unlawfully causes damage to another, intentionally or negligently, is obliged to compensate it. The limitation period here is more comfortable — Article 1008 gives three years from the moment the victim learned of the damage or of the person liable to compensate it.
In addition, Article 54 declares void any transaction that breaches a rule or prohibition established by law, or that contravenes public order or the norms of morality — which speaks directly to the unregistered activity described above.
IV. Practical instructions: what to do if you have already paid in
The order matters.
Step 1. Secure the evidence today — before the platform disappears
The defining feature of online schemes is that when they collapse, the website, the groups and the accounts all vanish. If that happens, you are left with no evidence. The essential minimum:
- Every document evidencing a transfer — bank statements, receipts, crypto transaction hashes (TxIDs) and wallet addresses;
- Dated screenshots of your personal account on the platform — balance, accruals, withdrawal requests and refusals (you may also use a notarial service for attesting facts);
- Correspondence with the recruiter or “leader”, and the promotional material circulated in the groups — this is exactly where the promised return is recorded, which is central to the element of deception under Article 180;
- The group name, administrators’ accounts and links — in archived form (screenshot plus link, not the link alone);
- Public promotional material — Facebook page posts, banners, the “signal schedule”, creatives depicting promised profits. This too is part of the evidentiary chain showing what you were promised.
Step 2. File a report of a crime
Under Article 101 of the Criminal Procedure Code, the ground for opening an investigation is information about a crime that has been provided to an investigator or prosecutor, has emerged during criminal proceedings, or has been published in the media; the information may be written, oral or recorded in any other way.
Article 100 then obliges the investigator and the prosecutor to open an investigation upon receiving such information. This is not a discretion.
Demand the certificate immediately. Article 101(2¹) gives a person who reports a crime the right to receive a written certificate confirming the report. That certificate will later be your only proof that you came forward.
Step 3. Request recognition as a victim
Filing a report and holding victim status are two different things. Under Article 56(5), the prosecutor issues the decision either on their own initiative or on the basis of your application. If the prosecutor has not granted the application within 48 hours of its filing, you have the right to apply once to a superior prosecutor, and if that is refused — to appeal to the district (city) court at the place of the investigation. The court rules on the matter within 15 days, with or without an oral hearing, and that ruling is not subject to further appeal.
This status is not a procedural formality — access to the case file and every subsequent lever depend on it.
Step 4. Raise the question of seizing assets — in good time
Under paragraph 1 of Article 151, the court may, on a party’s motion, seize the property of the accused, of a person materially liable for their actions, and/or of a person connected to them — including bank accounts — where there is data that the property will be concealed or spent and/or that it was obtained by criminal means. Where property obtained by criminal means cannot be located, the court is empowered to seize property of equivalent value.
Paragraph 3², added by Law No. 954 of 3 September 2025 (website, 05.09.2025), provides a separate ground: securing the payment of compensation to the victim — in which case the seizure also extends to property covered by Chapter XVII¹ of the Code. This is the mechanism that leaves a genuine chance of partial recovery — and its effect depends entirely on timing.
Step 5. Start a civil claim in parallel
Do not wait for the criminal case to conclude. The one-year period under Article 84 runs from the moment you learned of the deception — which means it has, in all likelihood, already started. A claim against a specific recruiter or a local legal entity under Article 992 is an independent route and does not require a verdict.
Step 6. Record the crypto trail
If the money was transferred in USDT or another virtual asset, the hash of each transaction remains on the public blockchain permanently — which, paradoxically, makes it stronger evidence than an ordinary transfer. Collect: sender and recipient wallet addresses, the network (TRC-20, ERC-20, etc.), the exact time and the amount. This material should be attached to your report.
Step 7. Notify the National Bank and inform your own bank
The National Bank cannot directly “regulate” an entity of the TSQ type — it sits outside the supervisory perimeter. However, under Article 52⁵(1)(f) the NBG is empowered to terminate or restrict a registered provider’s business relationship with platforms that create heightened money-laundering and terrorist-financing risk or that impede the traceability of transactions. Your notification becomes part of that picture.
Step 8. What you must not do under any circumstances
- Do not pay an “unblocking”, “commission”, “tax” or “verification” fee. Demanding more money in exchange for a withdrawal is a classic stage of collapse, not a technical problem.
- Do not turn to “fund recovery” services that appear on social media or inside the same groups. Secondary fraud (the recovery scam) hunts on lists of victims and causes more damage than the first one.
- Do not delete correspondence or records — however uncomfortable their content may be.
- Do not continue recruiting new people — including on the logic of “getting my own money back”. That is exactly where your own liability begins.
A realistic expectation. It has to be said plainly: full recovery in cross-border online schemes is rare. The organisers are as a rule abroad, and the assets are in virtual wallets. The real chance depends mainly on two things: (a) how quickly assets and accounts located in Georgia are seized, and (b) whether the circle of local beneficiaries — recruiters, “leaders”, local legal entities — is identified. Both depend on timing. A case opened several months after a scheme collapses is almost always futile.
V. Conclusion
TSQ’s specific legal fate in Georgia is not yet determined — there is neither a verdict nor a publicly known charge. But what this case has already exposed calls for an answer of its own.
First: Georgian legislation covers pyramid schemes adequately — but reactively, after the offence has been committed. The NBG’s supervisory perimeter extends to registered entities; anyone who never applies for registration and operates from a foreign website remains beyond preventive regulation. Here the only instrument is an informed citizen.
Second: three questions to put to any “investment offer”, most of which will go unanswered — where does the income come from, if not from new participants? Are you in the National Bank’s register? Who is the legally responsible person, and in which jurisdiction are they?
Third: if the money is already in, the decisive variable is time — for the seizure, for the limitation periods, and for preserving the evidence. In these cases, one week often matters more than the quality of the arguments.
Provisions cited
- Criminal Code of Georgia — Art. 25 (liability of perpetrators and accomplices), note to Art. 177 (monetary thresholds), Art. 180 (fraud), Art. 192 (illegal entrepreneurial activity), Art. 194 (legalisation of illegal income)
- Criminal Procedure Code of Georgia — Art. 56 (recognition as a victim), Art. 100 (duty to open an investigation), Art. 101 (information about a crime), Art. 151 (seizure of property)
- Civil Code of Georgia — Art. 54, Art. 81, Art. 82, Art. 84, Art. 976, Art. 992, Art. 1008
- Organic Law of Georgia “on the National Bank of Georgia” — Art. 39¹ (virtual asset), Art. 52⁵ (supervision of VASPs and mandatory registration)
- Law of Georgia “on the Securities Market” — Art. 3 (definition of a public offering)
Factual sources used
- IOSCO Investor Alerts Portal (I-SCAN), alert No. 39835 — “TSQ INVESTMENT GROUP LTD”, issued by Comisión Nacional del Mercado de Valores (Spain): iosco.org/i-scan/?id=39835
- National Bank of Georgia — “Financial pyramid”: nbg.gov.ge/page/pinansuri-piramida
- National Bank of Georgia — Virtual Asset Service Providers (VASPs) and the register: nbg.gov.ge
- “The National Bank warns the public about risks related to possible financial pyramids circulating on social media”, Imedi News, 26.08.2026: imedinews.ge
- “The amount Georgians have paid in is USD 30 million” — statement by Roman Gotsiridze, Timer.ge, 30.08.2026: timer.ge
- “TSQ is closing, counting its final days” — public warning, Palitra Video, 28.08.2026: palitravideo.ge
- “The NBG statement on fraudulent financial pyramids created confusion” — Roman Gotsiridze, Alia.ge: alia.ge
- “TSQ Currency Exchange” — public Facebook page; observed as of 1 September 2026: facebook.com/profile.php?id=61576529369194
- TSQ Investment Group — reviews on international platforms: Alertopedia, TradersUnion
Disclaimer. This article is a general legal analysis and does not constitute legal advice on any specific case. The factual assertions it contains belong to the sources indicated and are reproduced with attribution. As of the date this article was prepared, the author is not aware of any final court verdict or publicly announced charge in Georgia against TSQ Investment Group or any person connected to it; accordingly, every assessment concerning the fraudulent character of the scheme is of a presumptive nature. If you have been affected, consult a lawyer to develop an individual strategy.
