---
title: "Outsourced AML Officer for VASPs — Compliance Retainer"
url: "https://legal.ge/en/service/crypto-blockchain-services-en/outsourced-aml-officer-for-vasps-compliance-retainer-en"
field: "Crypto & Blockchain Services"
description: "Outsourced AML officer for VASPs: Article 29 compliance system, Article 11 thresholds and Article 12 procedure under Georgian law. Details: Legal.ge."
updated: "2026-10-15"
publisher: "legal.ge"
---

# Outsourced AML Officer for VASPs — Compliance Retainer

> Source: legal.ge, https://legal.ge/en/service/crypto-blockchain-services-en/outsourced-aml-officer-for-vasps-compliance-retainer-en

## 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.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/crypto-blockchain-services-en/outsourced-aml-officer-for-vasps-compliance-retainer-en

### Why does a virtual asset service provider need a compliance function?

Because Article 3 of the law on the suppression of money laundering and terrorism financing names the virtual asset service provider among accountable persons, and Article 29 requires every accountable person to implement a compliance control system and designate a responsible person.

### Which thresholds apply to one-off transactions?

The general threshold is 15,000 GEL or its equivalent in foreign currency, but for one-off transactions associated with convertible virtual asset services Article 11 sets a lower threshold: 1,000 US dollars, 1,000 euros or 3,000 GEL. For transfers of funds the threshold is 3,000 GEL.

### Can providers identify clients electronically?

Yes. Article 12 permits identification without face-to-face contact, electronically — under the procedure established by the supervisory authority and agreed operational procedures ensuring effective risk management. Anonymous and fictitiously named accounts are prohibited.

### What does outsourcing cover day to day?

Risk-based client assessment, threshold control, periodic review, detection of and reaction to suspicious transactions regardless of thresholds, updates to the internal instruction, and communication with the supervisory authority — all through the mechanism defined by Article 29.