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THE MODEL CHANGES THE WORK

VASP Business Models in Georgia

CONNECTED DELIVERY

Classify the regulated activity before you build the company around it.

Georgia’s VASP perimeter follows the functions actually performed by the operator. A single commercial product may combine exchange, transfer, custody, trading-platform, portfolio-management, lending or ICO-related services, and each function should be mapped separately.

REGULATORY PERIMETER

Seven core VASP activity categories — plus a separate stablecoin workstream

Commercial labels such as broker, remittance app, wallet, marketplace or yield product do not determine the legal classification. We map the actual customer journey, asset and money flows, control rights and provider roles to the Georgian statutory categories before the application model is fixed.

Exchange Transfer Custody / administration Trading platform Individual portfolio management Virtual-asset lending ICO-related services Stablecoin: additional framework
Company activity perimeter. The NBG states that a VASP is generally limited to virtual-asset services, activities necessary for providing them and exchange of its own virtual assets. Unrelated commercial activities should therefore be reviewed and structured deliberately rather than added to the VASP by default. See the registration framework.
SUPERVISORY CAPITAL

The service model determines the minimum

Exchange and/or transfer requires GEL 150,000; administration of a trading platform requires GEL 350,000; and other ordinary VASP services require GEL 250,000. A multi-service VASP applies the highest relevant threshold rather than adding the amounts together. At least 75% must consist of primary capital.

Crypto Exchange and Brokerage in Georgia

Classify exchange and brokerage execution roles, liquidity, custody, fiat settlement and counterparty responsibilities before the operating model is fixed.

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Crypto Custody and Wallet Services in Georgia

Establish who can control customer assets or control instruments and evidence key management, withdrawals, segregation, reconciliation and recovery.

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Virtual-Asset Transfer and Remittance in Georgia

Map virtual-asset transfer separately from any fiat payment leg, with counterparty, Travel Rule, sanctions, KYT and self-hosted-wallet controls.

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Virtual-Asset Trading Platform in Georgia

Define venue administration, matching, asset admission, conflicts, custody, settlement, resilience and records without conflating the platform with principal dealing.

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Virtual-Asset Portfolio Management in Georgia

Structure individual discretionary mandates, authority, custody, limits, valuation, fees and reporting while identifying collective-management or other perimeter overlap.

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Business Crypto Lending in Georgia

Confirm eligible business borrowers, collateral, custody, valuation, margin, liquidation, funding source and the VASP company’s permitted activity perimeter.

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ICO and Token-Offering Support in Georgia

Classify the token and each issuer/service role before offering, payment, custody, smart-contract governance, purchaser disclosures and secondary-market plans are finalised.

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Stablecoin Issuance and Services in Georgia

Plan prior NBG consent, Whitepaper, reserve backing and segregation, capital, issuance, redemption, reconciliation, resilience and monthly NBG reporting as a dedicated regulatory project.

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