LegalGELegalGE
...

E-Money Licensing

Do I need a physical office in Georgia?

Yes, the National Bank requires a real economic presence (substance), including a physical office and local management staff.

Can I serve international clients with a Georgian license?

Yes, but you must comply with the regulations of both Georgia and the countries where your clients are located.

What are the AML requirements?

You must have a robust Anti-Money Laundering policy, a dedicated AML officer, and software for transaction monitoring and sanctions screening.

Is crypto considered e-money in Georgia?

No, cryptocurrency is distinct from e-money. Crypto businesses need a separate VASP (Virtual Asset Service Provider) registration.

Reading Time

3 min

Published

...

E-Money Licensing is a mandatory authorization for companies wishing to issue digital wallets, prepaid cards, or other payment instruments in Georgia. With the development of the FinTech industry, the National Bank of Georgia (NBG) has significantly refined and tightened regulations. The Law of Georgia on Payment Systems and Payment Services defines requirements for capital, management suitability, and anti-money laundering (AML) mechanisms. Obtaining a license is a complex and multi-stage process requiring not only financial resources but also flawless legal and technical documentation.

Georgia is an attractive jurisdiction for international fintech companies due to its liberal tax environment and modern banking infrastructure. However, failure to meet the regulator's (NBG) requirements leads to refusal of registration or revocation of an existing license. Legal.ge offers access to banking and financial law experts who will guide you through the entire licensing process — from application submission to the start of operations.

What does the E-Money Licensing Service cover?

The service ensures full legal support:

  • Preliminary Consultation: Analyzing the business model — do you need a Payment Service Provider (PSP) license or an Electronic Money Institution (EMI) license.
  • Documentation Preparation: Drafting business plans, structural charts, AML/CFT policies, IT security policies, and risk management documents according to NBG standards.
  • Fit & Proper Checks: Documentary justification of directors' and beneficial owners' compliance with "Fit & Proper" criteria.
  • Capital Formation: Legal support for forming minimum authorized capital and proving the origin of funds.
  • Communication with NBG: Correspondence with the National Bank, answering queries, and representation at meetings.
  • Testing Mode: Assistance in setting up the system in a test environment and passing audits.

Common Real-World Scenarios

Licensing is required in the following cases:

  • E-Wallet: A startup creates an app where users can store funds and pay each other.
  • Payment Gateway: A company offers online stores a service for accepting payments.
  • Terminal Network: Operating self-service terminals (PayBox) for utility and other payments.
  • Money Remittance: Implementing a money transfer system.

Legal Framework: Capital and Regulations

Under National Bank of Georgia regulations, different requirements apply to Payment Service Providers (PSPs) and Electronic Money Issuers (EMIs). For example, minimum capital for a PSP may be lower, while requirements for an EMI issuing e-money are significantly higher. Strict compliance with the Law on Facilitating the Prevention of Illicit Income Legalization is mandatory. The registration process can take several months, and the fee depends on the type of activity.

Step-by-Step Service Process

The process includes the following key stages:

  1. Preparatory Stage: Setting up the corporate structure and depositing capital.
  2. Application Submission: Submitting the full package to the National Bank.
  3. Review: Addressing NBG comments and adjusting documentation.
  4. Inspection: On-site inspection of technical and software infrastructure by NBG.
  5. Obtaining License: Starting operations and maintaining supervisory reporting.

Why choose a specialist on Legal.ge?

Licensing is not just filling out forms; it is gaining the trust of the state regulator. An incorrectly prepared AML policy or opaque ownership is grounds for guaranteed refusal. Lawyers on Legal.ge will help you navigate this complex bureaucratic path smoothly and launch your fintech business in Georgia successfully.

Updated: ...

Specialists for this service

Loading...