What an Outsourced Compliance Function Is and Who Needs One
The Law of Georgia on Facilitating the Suppression of Money Laundering and the Financing of Terrorism imposes on accountable persons the obligations to apply preventive measures and to implement a compliance control system. Inside those obligations sits concrete, day-to-day work: identifying and verifying customers, assessing risks, maintaining the internal instruction, training employees and preparing for independent audit. Precisely this work can be handed to an experienced specialist under a retainer (outsourcing) format — a recurring service in which the compliance function is performed not by an in-house employee but by a provider acting in the name of the accountable person and under its internal instruction.
This format is particularly relevant for virtual asset service providers. Article 3 of the law lists, within the group of financial institutions, the virtual asset service provider by name. The same article brings currency exchange bureaus, microfinance organisations, payment service providers and others into the circle of accountable persons, yet the virtual asset sphere stands apart because the law sets a distinctly lower identification threshold for one-off transactions associated with it — more on this below.