Fintech and VASP Lawyers in Georgia
A fintech or virtual-asset project should establish its Georgian regulatory perimeter before product launch, marketing or customer onboarding. Technology labels do not determine the legal classification.
What our fintech & vasp work covers
We advise fintech, payment and virtual-asset businesses on Georgian structure, VASP registration preparation, AML/CFT governance, ownership and management, customer terms, outsourcing, data, safeguarding interfaces and regulator-facing documentation.
Legal and commercial context
Georgia's VASP regime has applied since 1 January 2023. NBG states that registration is mandatory for VASP activity and that registered providers are subject to fit-and-proper and AML/CFT supervision. Virtual assets are not legal tender, and the payment uses permitted by law are limited; product analysis must therefore follow the actual flow of funds and assets.
The framework continues to develop. NBG amendments effective in 2026 require visible evidence of registration, and NBG announced a stable virtual asset framework requiring full reserve backing, segregation, redemption, disclosure and operational controls. Current rules should be checked at the time of application and launch.
Scoping the decision, evidence and completion record
At the start of this instruction, counsel separates the immediate commercial decision from longer-term remediation. For fintech & vasp, the initial workstreams usually connect regulatory perimeter, entity and governance and registration pack. They are sequenced around the first agreed step—document the product and transaction flow without relying on marketing labels.—so management knows which conclusion is needed now, which issue is a dependency and which improvement can follow after the transaction or operating decision.
The evidence file should remain intelligible to a director, investor, bank, auditor or regulator who was not present during the original discussions. It therefore links product and funds-flow diagrams, business plan and financial model, owner, beneficiary and manager information and system architecture and outsourcing contracts to the factual assumptions and applicable public sources. Counsel tests that record for risks such as activity begins before classification or registration, a group licence is assumed to cover Georgia and product description differs from actual flows and records unresolved points rather than silently treating them as confirmed facts.
Completion is defined by usable output, not the delivery of a generic memorandum. Depending on scope, the closing record will include regulatory-perimeter memorandum, registration readiness report and governance and authority pack and an implementation list showing approvals, signatories, filings, notices, owners and dates. Any conclusion that depends on tax, accounting, technical evidence or foreign law is identified with the responsible specialist and the date on which that dependency must be resolved.
Workstreams designed around the business decision
Regulatory perimeter
Map each product, customer, asset, payment and custody flow against Georgian definitions and restrictions.
Entity and governance
Design ownership, management, fit-and-proper evidence, authority and local control arrangements.
Registration pack
Coordinate policies, business description, systems evidence and application materials required for the proposed activity.
AML/CFT framework
Prepare risk assessment, onboarding, monitoring, escalation, reporting and record controls with qualified compliance input.
Customer documents
Draft terms, disclosures, complaints, risk information, privacy and product-specific consent records.
Operations and outsourcing
Allocate security, resilience, data, audit and regulator-access responsibilities across vendors and group companies.
How the legal work is organised
- 1
Document the product and transaction flow without relying on marketing labels.
- 2
Issue a regulatory-perimeter and gap analysis against current NBG and statutory materials.
- 3
Confirm structure, owners, managers, compliance resources and technical dependencies.
- 4
Prepare application, governance, AML, customer and outsourcing documents.
- 5
Support regulatory questions, launch controls and an update process for rule changes.
Documents and evidence to prepare
The exact request is tailored to the matter. A first review commonly starts with:
- product and funds-flow diagrams
- business plan and financial model
- owner, beneficiary and manager information
- system architecture and outsourcing contracts
- AML/CFT risk assessment and procedures
- customer journey, terms and disclosures
- data map and security incident process
- capital, reserve or safeguarding evidence where applicable
Risks we test
Legal review focuses on consequences that can affect authority, value, timing, compliance or enforceability:
- activity begins before classification or registration
- a group licence is assumed to cover Georgia
- product description differs from actual flows
- AML procedures are generic and unresourced
- outsourcing obscures responsibility or regulator access
- 2026 framework changes are omitted from launch planning
Typical deliverables
The agreed deliverable should help the company act, obtain approval and retain a reliable record of the decision.
Official public sources
These links are starting points for the current public legal framework. The operative consolidated text, amendments and facts should be checked when advice is given.