Virtual Asset Service Provider Licensing

Introduction: VASP Licensing Procedure

VASP licensing (registration) is a mandatory procedure for any entity offering cryptocurrency exchange, transfer, or custody services to users in Georgia. The National Bank of Georgia sets strict market entry criteria to ensure financial system stability and prevent money laundering. "Virtual Asset Service Provider Licensing" is a targeted service focused specifically on preparing the registration application and successfully obtaining authorization from the National Bank. This process often takes 4 to 6 months and requires perfection in not only legal but also technical and operational documentation.

Involving an experienced lawyer significantly increases the likelihood of obtaining the license, as the regulator often rejects applicants due to incomplete information or inappropriate corporate structure. Our service includes full support: from filling out application forms to receiving the license.

What VASP Licensing Services Cover

The service covers all registration stages defined by the National Bank:

• Documentation Package: Preparing the full registration package, including: Business Plan, Operational Manual, AML/CFT Policy, and Risk Management Rules.
• Fit & Proper Check: Preparing dossiers for directors and beneficial owners to meet the National Bank's suitability criteria (criminal record, education, reputation).
• Office and Technical Infrastructure: Verifying head office compliance and documenting the audit of electronic systems (monitoring software).
• Capital Verification: Justifying the source of financial resources (often the most challenging part).
• Regulator Communication: Providing timely and competent answers to questions (deficiencies) raised by the National Bank.
• Interview Preparation: Preparing company management for meetings with National Bank representatives.

Common Scenarios and Use Cases

Licensing services are critical in the following cases:

• Foreign Exchange Branch: A global crypto exchange opens a subsidiary in Georgia and wants a local license to establish a regional hub.
• Local Startup: Georgian founders create a crypto wallet and need authorization for legal operation.
• Crypto ATM Operator: A company wants to deploy a network of terminals, which requires VASP registration.
• Appealing a Rejection: A company attempted registration independently, was rejected, and needs professional legal help to correct deficiencies and reapply.

Georgian Legislation and Regulations

The licensing process is regulated by Order No. 165/04 of the President of the National Bank of Georgia ("Rule for Registration of Virtual Asset Service Providers"). This order details the required documents and the timeline for application review. The Law on Facilitating the Prevention of Money Laundering and the Financing of Terrorism also applies, setting integrity standards for administrators. The registration fee is 5,000 GEL, though legal service costs are separate.

Process of Working with a Specialist

The licensing stages are:

1. Preliminary Audit: Assessing company readiness (capital, staff, IT).
2. Document Drafting: Creating policies and procedures (approx. 1-2 months).
3. Application Submission: Uploading documents to the National Bank portal.
4. Deficiency Stage: Addressing regulator comments and corrections.
5. Registration: Receiving the registration certificate and reflection in the Public Registry.

Why Choose Legal.ge?

VASP licensing is a high-complexity bureaucratic process. Legal.ge partners with lawyers who have a 100% success rate in VASP registrations. We know what the National Bank looks for and how to prepare your company for a guaranteed result.