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Crypto Exchange Licensing

What is the minimum capital to start a crypto exchange in Georgia?

There is no fixed statutory minimum capital, but the NBG requires proof of financial sustainability, typically covering at least 6-12 months of projected operating expenses.

Can I operate a global exchange from Georgia?

Yes, a Georgian VASP license allows you to serve international clients, provided you comply with Georgian AML laws and do not target jurisdictions where such services are banned.

Is software audit mandatory?

Yes, you must demonstrate to the NBG that your platform has robust cybersecurity measures and transaction monitoring capabilities (often via third-party providers).

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Introduction: Crypto Exchange Registration Process in Georgia

Crypto Exchange Licensing (legally referred to as registration) is one of the most high-profile legal services in the fintech sector. Georgia attracts crypto investors with its liberal tax regime, but opening a crypto exchange requires meeting strict regulatory requirements. The National Bank supervises any platform that converts virtual assets or administers a trading platform. This service involves full legal support for establishing a crypto exchange: from company registration to obtaining VASP authorization from the National Bank.

Operating an unlicensed crypto exchange in Georgia is illegal and subject to severe sanctions. For investors wishing to create a global or local trading platform, the involvement of an experienced legal team is critical to ensure compliance with international standards (FATF, AML) and Georgian legislation.

What Crypto Exchange Licensing Services Cover

This is a complex service spanning several months, covering:

  • Corporate Structuring: Establishing a legal entity specifically for the exchange, drafting Shareholders' Agreements.
  • Fit & Proper Testing: Preparing directors and beneficial owners for National Bank scrutiny (no criminal record, qualifications, reputation).
  • AML/CFT System Setup: Implementing internal controls for anti-money laundering, creating risk assessment matrices.
  • Operational Documentation: Preparing Terms of Use, Privacy Policy, and Risk Disclosure documents for users.
  • IT Audit Support: Working with the technical team to meet cybersecurity standards (a prerequisite for registration).
  • Representation at National Bank: Submitting the registration application, communicating with the regulator, and answering inquiries.

Common Scenarios and Use Cases

Crypto exchange licensing is relevant for the following types of projects:

  • Centralized Exchange (CEX): A platform that holds user funds (Custodial) and offers trading pairs (e.g., BTC/GEL, ETH/USD).
  • P2P Platform: A marketplace where users exchange crypto with each other, while the platform acts as an Escrow agent.
  • Brokerage Service: A company that buys crypto on large international exchanges (Liquidity Providers) on behalf of clients and sells it for a commission.
  • Crypto Payment Aggregator: A system allowing businesses to accept payments and automatically convert them.

Georgian Legislation and Regulations

Crypto exchange activities are directly regulated by the Order of the President of the National Bank of Georgia on VASP Registration. This normative act establishes that exchange administrators must be fit and proper persons. Additionally, the Law on Facilitating the Prevention of Money Laundering and the Financing of Terrorism imposes reporting obligations on exchanges to the Financial Monitoring Service. The Law on Personal Data Protection is also crucial, as exchanges process sensitive user data (KYC).

Process of Working with a Specialist

Exchange licensing is a complex, multi-stage process:

  1. Preparatory Stage: Drafting a business plan and verifying capital.
  2. Corporate Stage: Establishing the company and renting/setting up an office.
  3. Documentation Stage: Preparing a package of policies and procedures (200-300 pages).
  4. Registration Stage: Submitting the application and undergoing National Bank checks.
  5. Post-Registration: Launching in test mode and opening bank accounts (often the hardest part).

Why Choose Legal.ge?

Opening a crypto exchange is not just about writing software code; it is about creating a financial institution. Legal.ge offers access to top lawyers with practical experience in obtaining VASP authorization. Our specialists will help you not only get the "license" but also build a sustainable and legal business.

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