“We’re in the process of launching a crypto-based platform” isn’t the most precise description of a regulation application.
Can customers exchange crypto for fiat currencies? Will the platform be able to move virtual assets? Will the company control client wallets and private keys? Is it planning to run the trading platform or lend against digital assets?

Those differences matter when pursuing a crypto license in Georgia because the services a company intends to provide affect its regulatory preparation, documentation, controls, and capital requirements.
Georgia is an ideal location for fintech companies, but to be able to access its controlled virtual asset market, you need more than just registering your business and creating a website.
Defining the nature of service
Businesses that offer virtual asset services to third party according to the model described in PB Services must register with the National Bank of Georgia as Virtual Asset Service Providers.
This covers virtual asset transfer and exchange, the administration of trading platforms, as well as custody or management of cryptocurrency. The important thing to note is that the regulation states that the custody concept is also applicable to the management of a user’s private key or wallet.
The technical design of a crypto-product relevant to its regulatory status.
Before submitting an application for a license, a founder who is seeking an e-currency license in Georgia must outline the customer’s journey. What happens when a customer makes a deposit of their funds? Who controls your wallet? Are assets able to be exchanged or transferred? Which party is authorized to authorize transactions?
The clarity of the answers can help to determine what the company will do.
Your Business Plan must describe the real business
A VASP application requires more than an attractive pitch deck.
Based on the information provided, according to the information provided, National Bank requires a detailed plan of business with financial projections covering a minimum period of three years. They include expenses, revenue, and growth expectations. The plan should also show the genuine intent to operate in Georgia.
This requirement should be addressed early.
A business plan designed for investors will answer the following questions: How quickly will the company expand? A business plan that is regulated must include a description of how the operation will operate in a safe manner.
If a company is that are looking for a license to use vasp Georgia applicants must be able to connect the commercial model with the compliance model, rather than thinking of them as separate documents.
AML is not able to be added at the End
PB Services has described the procedure of preparation as a significant part of which are the controls to stop financial crime and the financing of terrorists.
The information warns explicitly that importing an AML Policy from another jurisdiction will not be enough as Georgian requirements must be incorporated into a business’s framework.
It is equally important to look at the operational systems. The business plan should show that the system used by the firm can identify suspicious transactions.
It is essential to consider compliance as a factor in product development. It is not advisable to create a platform prior to deciding on how AML policies are to be implemented. This could result in delay and unnecessary changes.
Capital is Dependent on the services you select
The need for regulatory capital is a further reason to establish the business model earlier.
In accordance with the guidelines in the document Exchange and transfer activities which include kiosks, are required to be 150,000 GEL. Trading-platform management requires 350,000 GEL however other covered services are only required to be 250,000 GEL. The most stringent thresholds apply when a variety of services are offered.
This is distinct from operating capital or capital invested. Documentation that proves the required amount has actually been funded must be included with the application and the capital has to be maintained throughout the course of operations.
The founder that wants to apply for a crypto-blockchain licence in Georgia should consider the regulatory capital in his budgeting process and not wait until the rest has been completed.
Registration doesn’t complete the compliance process.
The approval is not the point where the compliance calendar disappears. The obligations include ongoing obligations related to risk management, cybersecurity and technology resilience. They also address records retention, independent reviews of customer complaints and records retention.
For example an opinion of an independent auditor regarding the risk-management framework has to be sought within 12 months of the date of registration. In accordance with the regulations, companies are required to take complaints in written or oral form and must review them within one month. They must also send statistics of complaints to the National Bank electronically each month.
The details of these changes affect how a serious applicant should approach licensing.
Imagine that you are using a Georgian VASP Application as the style of a legally regulated business.
It is crucial that the structure of the company, technology, AML controls and regulatory capital, in addition to customer processes, are all in perfect alignment.
Georgia is a good location for crypto and fintech companies. Its regulatory framework provides a well-defined path to the market. The best place to start isn’t asking how quickly a license can be obtained.
It’s about being able with specificity, detail what your crypto company plans to do and to demonstrate that the company will be doing it within Georgia’s legal framework.