Registration is not the finish line. A Georgian VASP must continue to operate through the people, office, systems, policies and controls presented to the NBG, while keeping evidence that management can review and the supervisor can inspect.
Maintain the operating baseline
- Governance and fit-and-proper administrators.
- Operational head office and required physical presence.
- Working KYC/KYB, sanctions, PEP and KYT controls.
- Customer, transaction, case, audit and reconciliation records.
- Risk assessment, reporting calendar and staff competence.
- Incident response, business continuity and cybersecurity controls.
Control material changes before implementation
Changes to ownership, administrators, service models, branches, websites/apps, providers, systems or material AML risks may require approval or notification. The change process should begin at product design, not after launch.
Make registration visible
The NBG registration administrative act must be visible or easily available across the channels through which services are provided, including the head office, branches, kiosks, website and application.
Protect the value of registration
False documentation, repeated reporting failures, serious or systemic breaches, inadequate unusual-transaction detection, obstruction of supervision, missing office/staff, failure to commence or prolonged inactivity can threaten the registration. Managed compliance should focus on evidence and corrective action, not calendar reminders alone.