Who is a virtual asset service provider
With the growth of the digital economy, Georgia has built a clear regime for virtual asset service providers — the category known internationally by the abbreviation VASP. In plain terms, a virtual asset service provider is any natural or legal person that offers services connected with virtual assets to customers: exchanging virtual assets for fiat currency or for other virtual assets, transferring them, safeguarding and administering them, or participating in and providing financial services related to the offer and sale of a virtual asset. This page explains who falls within the definition, who must register with the National Bank of Georgia, and how this overview relates to the specialised guides of our crypto practice. It is the map; the registration journey itself is described in our dedicated licensing guide.
The definition matters because the law attaches consequences to it. A person that answers the definition is an accountable person within the Georgian framework for the prevention of money laundering, must register with the National Bank before providing services, and remains under ongoing supervision afterwards. A person that does not answer the definition — for example, a purely technical developer that never touches customer assets — stands outside the regime, although the boundary questions are often subtle enough to require a legal opinion.
The services that create VASP status
The circle of covered services is best understood through practical examples:
- Exchange services: platforms and desks that convert virtual assets into fiat currency or into other virtual assets, whether against the provider’s own account or as an intermediary between customers.
- Transfer services: moving virtual assets from one customer or platform to another where the provider participates in the transaction as a business.
- Custody and administration: safeguarding of virtual assets, keys or wallets for clients, and the administration of portfolios or instruments built on virtual assets.
- Issuance-related services: participation in the offer and sale of a virtual asset and the provision of related financial services.
A single product often combines several of these services — a trading platform with built-in wallets is simultaneously an exchange, a transfer participant and a custodian — and it is the combined activity that the regime looks at as a whole.
Who must register with the National Bank of Georgia
The Georgian framework does not leave the choice to the provider. It is impermissible to provide virtual asset services through a person that is not registered with the National Bank or is not otherwise empowered by the legislation regulating its own financial-sector activity. Registration is therefore a condition of operating, not an optional mark of quality. The rules of registration, deregistration and regulation are established by a normative act of the National Bank, and the Bank examines the ownership, the source of capital and the fitness of the people who will run the provider.
Foreign groups reach the same door: a group that wishes to serve the Georgian market through a local entity registers that entity, and the expectations regarding genuine management and control apply to it in the same way as to a founder’s start-up. Questions of physical presence, responsible officers and internal controls are resolved in the course of the registration process rather than by a single fixed checklist, which is precisely why an early legal analysis of the business model saves months later.
What an unregistered provider risks
Operating without registration is not a grey zone. The supervisory framework authorises the National Bank to restrict or suspend unregistered activity, to demand information and to apply sanctions; unregistered operation may also attract liability under other legislation, including criminal legislation, where the underlying conduct amounts to an offence. In commercial terms the practical damage usually arrives earlier than any sanction: partner banks decline the relationship, and counterparties ask for proof of registered status before the first transaction.
How this overview relates to our licensing guide
This page answers the question of definition and coverage. The registration process itself — the full cycle with the National Bank of Georgia, from the analysis of the business model to the completed registration and the obligations that follow — is the subject of our dedicated guide on VASP licence in Georgia: registration with the National Bank. Exchange operators should also read the crypto exchange licensing page; the compliance file that a registered provider maintains is described in our AML/KYC policy documentation service; and the wider framework is mapped in the Georgia crypto regulation briefing.
Frequently asked questions
Does every crypto business need to register?
If the business provides services over customers’ virtual assets — exchange, transfer, custody, administration or issuance-related services — registration with the National Bank is mandatory. A business that only builds technology, publishes analysis or trades for its own account does not answer the provider definition, although mixed models deserve a legal opinion.
Is a wallet automatically a VASP?
A wallet that the provider safeguards or administers for clients brings the provider within the definition. A non-custodial wallet, in which the user alone holds the keys and the supplier never controls the assets, stands outside it — but the surrounding services of the same product may change that answer.
Can a foreign company register?
Yes, through an entity that operates in Georgia and satisfies the National Bank’s requirements regarding ownership, the origin of capital and management. The analysis of which entity to register is part of the preparation for the application.
What continues after registration?
Supervision: ongoing compliance with the Bank’s requirements, internal control obligations and the preventive measures of the anti-money-laundering framework. Our page on regulatory engagement describes how this relationship is managed in practice.
How we help on Legal.ge
On Legal.ge we bring together lawyers who work with the virtual asset framework daily. We analyse whether a business model falls within the provider definition, prepare the legal opinion that answers the question and — where registration is required — carry the matter into the full registration cycle together with our licensing team. Choose a specialist today on Legal.ge.