The Legal Basis That Exists — and Its Exact Boundaries
Banking access for a crypto business in Georgia is often discussed emotionally, so it is worth starting precisely with what the law actually says. The law on the payment system and payment services establishes: a payment-service provider registered by the National Bank of Georgia has the right to open a payment account with a commercial bank and to have access to services through that payment account on an objective, non-discriminatory and proportional basis. The access must enable the payment-service provider to carry out payment services smoothly and effectively.
The same norm contains a defensive mechanism: where such access is refused, the commercial bank is obliged, within no more than 7 calendar days of the refusal, to provide the National Bank of Georgia with information about it and a well-founded justification. In other words, a refusal must be communicated and justified in a form transferred to the supervisor — this creates the balance around which this whole page is built.
What the Law Does Not Regulate — the PSP Right and the Absence of a VASP Right
Here lies the decisive, often overlooked detail: the right described above belongs to a payment-service provider registered with the National Bank. A virtual asset service provider (VASP) licensed or registered under the virtual-asset framework does not, by that fact alone, become a payment-service provider: the law establishes no right of access to a bank account for a virtual asset service provider as such. Accordingly, even where your crypto business is fully legitimate and regulated, the law gives it no guarantee of account opening.
In practice the distinction reads as follows: if your company provides payment services and is registered in that status, your relationship with the bank is governed by the statutory standard — objectivity, non-discrimination and proportionality — and by the justified form of any refusal. But if your activity exists only in the VASP format, banking access remains within each bank’s own policy: every bank decides for itself whether to serve the crypto segment, on what terms and with what documents.
What This Means for a Crypto Business — the Reality of Bank Policy
In practice this implies two realities you must face directly. First, banks’ attitudes to the crypto segment differ: some are open to thoroughly reviewed applications from this segment, others abstain even without stating a reason, because opening an account is a contractual relationship and the bank manages its portfolio through its own risk assessment. Second, at the centre of a successful application stands not an argument about rights but a picture the bank can understand and verify — who owns the company, what it does, from what sources funds arrive, and how the company manages its communications perimeter. The concrete requirements, tariffs and review timelines are defined by the bank’s policy — confirm them with the bank before filing.
Accurate information pays for itself here: a wrongly chosen bank, an incomplete application or unprepared answers trigger refusals in the crypto segment more often than in other industries, and each refusal costs time and reputational capital.
The Compliance File — What We Prepare for You
The central product of our service is precisely the compliance file — a package of documents and explanations that prevents the bank’s assessment from falling into misunderstanding. The file includes: materials reflecting the company’s structure and ownership; the status of licences and registrations — including documentation confirming VASP status; a description of the activity — how the company earns revenue and with what types of clients it works; the profile of income sources and expected transactions; confirmation of the existence of internal anti-money-laundering policies; and prepared answers to the bank’s likely questions. Such a package gives the bank the means to assess your business as transparent — and that is exactly what accelerates decision-making in the crypto segment.
Our Service — From Assessment to the Bank
The full cycle looks like this: at the first stage we analyse your activity and determine whether it falls within the framework of payment-service provider registration — if it does, the statutory standard of objectivity and non-discrimination applies in the banking relationship; if not, the work proceeds within the reality of bank policies. We then prepare the compliance file, select the banks that genuinely fit your profile and submit the application with accompaniment — we even prepare answers to the bank’s questions in advance. On licensing matters — if you do not yet hold VASP status or wish to extend it — see our separate page "Virtual Asset Service Provider Licensing".
Frequently Asked Questions
Below we answer the most frequently asked questions about banking access for a VASP or crypto business.
Does a VASP have a statutory guaranteed right to a bank account?
No. The statutory right of access — on an objective, non-discriminatory and proportional basis — belongs to a payment-service provider registered with the National Bank. VASP status does not automatically confer that right; account access for a crypto business is a matter of bank policy.
What happens if a bank refuses access to a payment-service provider?
In that case the commercial bank must, within no more than 7 calendar days of the refusal, provide the National Bank with information about it and a well-founded justification. This gives the refusal a transparent form.
Why do banks decline crypto businesses?
Because opening an account is a contractual relationship and the bank manages its portfolio through its own risk assessment; the law does not separately regulate account access for this segment. The decision depends on each bank’s policy — confirm the concrete terms with the bank.
How do I increase the chances of opening an account?
With a prepared compliance file: transparent ownership structure, licence status, description of the activity and income sources, transaction profile and confirmation of anti-money-laundering policies. The right bank and a complete package are decisive.
How We Help You on Legal.ge
If you run a crypto business and need a bank account — contact us. At the first consultation we will assess your status, determine which framework fits your activity, prepare the compliance file and bring the application to the bank with accompaniment on Legal.ge.