The Legal Foundation for Organising Payments
For a gambling operator, banking relations and the organisation of payments are not merely a technical matter: they rest on an entire infrastructure regulated by the Organic Law of Georgia on the National Bank of Georgia. The National Bank is the institution that builds the mechanism of clearing, settlement, payment services and payment systems, leads them and supervises them. This page explains what powers the National Bank holds in this field, how the institution of clearing and payment agreements works, and why it is critical that a virtual asset is not a lawful means of payment in Georgia.
From a practical standpoint, if your operations include player deposits, the payment of winnings, cash flows across a retail network of cash desks and settlement with foreign partners, your payment architecture must be assembled precisely within this lawful framework — otherwise compliance costs and risks rise sharply, and the reliability of every transfer comes into question.
The Institution of Clearing and Payment Agreements
Article 62 of the Organic Law provides that the National Bank is authorised to conclude clearing and payment agreements, or for the same purpose any other contract, with foreign state and private central clearing institutions — both in its own name and in the name and on behalf of Georgia. This norm underpins the infrastructure of international settlement: payments going abroad or arriving from abroad ultimately rely on the channels provided for by these agreements.
For your payment flows to be dependable, what matters is which payment service providers you work with and under what rules settlement occurs between them. The National Bank’s international agreements define the base on which these channels are built, and this is why knowing them matters when organising payments at scale.
Regulation and Supervision of Payment Systems
Under Article 63, the National Bank is authorised, at its own discretion, to develop and issue legal acts regulating clearing, settlement, payment services and payment systems, and to establish the relevant rules and requirements. The same norm connects this to organisational functions: the National Bank organises the creation and deployment of payment systems in Georgia, manages and ensures the servicing and administration of these systems, assists other banks in creating payment systems, and supervises the payment systems and payment services operating in Georgia.
The National Bank also operates a securities settlement system: it may register in this system securities issued in Georgia, ensure their settlement through the system, and open accounts for the Government of Georgia, a foreign government, a central bank, a central depository, a custodian service provider and other financial institutions, while also defining the relevant rules and criteria. For an operator, this means that the choice of a payment services provider, and its status, must be verifiable within this regulatory framework — a provider operating under the National Bank’s rules is a fundamentally different risk category from an informal channel.
The Virtual Asset and Its Prohibition
Article 39-1 contains two principled provisions. First: a virtual asset is not a lawful means of payment. Second: making payments with a virtual asset is prohibited, except for those cases determined by a legal act of the National Bank of Georgia that are necessary for carrying out virtual asset services. In the gambling business, where the temptation toward a crypto layer is particularly strong, this prohibition means that accepting deposits or paying winnings in a virtual asset is directly unlawful as a payment scheme.
An exception is possible only where the specific operation falls within the cases determined by a legal act of the National Bank and concerns the provision of virtual asset services. Therefore, before adding a crypto component to your payment product, it is essential to verify whether the relevant norm exists and what exactly the National Bank has permitted — assumptions in this area are worth nothing, and the boundary between a regulated service and a prohibited payment is thin.
Structuring an Operator’s Payment Architecture
A properly built payment architecture for an operator means separating three contours: player-facing payments (deposits and withdrawals), operational cash management across the retail network of cash desks, and intra-group settlement with international partners. Each contour relies on payment systems that the National Bank regulates and supervises, and each requires its own contractual base with banks or payment service providers.
At the same time, when organising banking relations, keep in mind that the rules and requirements applicable to payment systems change through legal acts issued at the National Bank’s discretion. Documenting payment processes and revisiting them periodically is therefore just as important as concluding the agreements themselves — a structure that was defensible at the moment of launch may quietly drift out of compliance as the regulatory acts evolve.
Frequently Asked Questions
Can winnings be paid to a player in cryptocurrency?
No. A virtual asset is not a lawful means of payment, and making payments with a virtual asset is prohibited, except for cases determined by a legal act of the National Bank that are necessary for virtual asset services.
Who regulates payment systems in Georgia?
The National Bank: it issues regulatory legal acts, organises the creation and deployment of systems, manages, services and administers them, assists banks, and supervises operating payment systems and payment services.
With whom does the National Bank conclude clearing agreements?
With foreign state and private central clearing institutions, both in its own name and in the name and on behalf of Georgia; any other contract for the same purpose is also possible.
Why does the payment provider’s status need to be verified?
Because payment services and systems are subject to the rules and requirements established by the National Bank, which also supervises them — the provider’s status defines the lawful margin within which your payments operate.
How We Help on Legal.ge
We will review your payment architecture through the lens of National Bank regulations, assist in preparing banking and payment agreements, assess the lawfulness of a crypto component and design compliance procedures. Contact us on Legal.ge so that your payment organisation is built on a reliable foundation from the outset.