Exchange projects are classified by what the Georgian entity actually does, not by whether the product is marketed as an exchange, broker, OTC desk or liquidity service.
We map the statutory exchange activity against the execution model, contracting party, pricing, liquidity, custody, fiat settlement, reconciliation and financial-crime controls so the application and operating model describe the same business.
Regulatory classification
A commercial brokerage label does not create a separate VASP category. The legal analysis turns on whether the Georgian entity exchanges convertible virtual assets, routes or executes transactions for another person, controls customer assets or operates another regulated function.
- Statutory activity mapping
- Principal or agency execution
- Asset, wallet and fiat control
- Liquidity, sanctions and transaction monitoring
Define the execution role before documenting the controls
Principal dealing, agency execution, OTC intermediation and routed execution create different contractual, balance-sheet, conflict, settlement and AML evidence. The application should identify who is the customer counterparty at every step.
Required operating evidence
The evidence set should connect customer onboarding, order capture, price formation, liquidity providers, wallet and bank accounts, execution, settlement, reconciliation, fee calculation and exception handling to named systems and accountable personnel.
Principal control risks
Exchange risk concentrates around misclassified execution roles, opaque liquidity arrangements, customer-asset control, fiat dependencies, settlement breaks, conflicts of interest and monitoring that does not reflect actual transaction volumes or corridors.
Commercial labels do not determine the perimeter
Calling the service a broker, swap desk or liquidity gateway does not resolve the regulatory analysis. Contracts, wallets, bank accounts and system permissions must show who performs each regulated step and who bears the resulting risk.
Supervisory capital
A VASP providing exchange and/or transfer services maintains at least GEL 150,000 in supervisory capital. If the same entity adds a service subject to a higher threshold, the highest applicable amount governs. At least 75% of the minimum must consist of primary capital.
Scope of our engagement
Our exchange work can cover regulatory classification, transaction-flow mapping, principal/agency documentation, liquidity and counterparty framework, custody and settlement design, AML/KYT requirements, application evidence and implementation coordination. The scope is agreed around the actual model and dependencies rather than a generic licence package.
Classification decision
Fix the regulated activity, execution role and perimeter overlaps before the application narrative is drafted.
Evidence package
Tie execution, liquidity, custody, fiat settlement and monitoring claims to contracts, systems, owners and testable records.
Operational consequence
Carry the approved model into banking, provider onboarding, reconciliation, disclosures and supervised operations.
Exchange operating chain
A practical sequence used to test whether contracts, systems, providers and control ownership describe the same service.
Issues to resolve before filing
It determines who contracts with the customer, owns or sources the traded asset, sets or transmits the price, bears settlement exposure and earns the spread or commission. The contracts, accounting, liquidity evidence, conflicts framework and AML controls should all match that role.
Not by itself. Brokerage is a commercial description. The legal classification follows the functions actually performed by the Georgian entity, including exchange, transfer, custody or another regulated virtual-asset service.
Record each counterparty’s legal identity, jurisdiction, contractual role, onboarding status, pricing method, settlement path, wallet and bank-account ownership, sanctions/AML diligence, limits, concentration, incidents and fallback arrangements.
The team should be able to trace customer acceptance, funding, order capture, pricing or routing, execution, custody, fiat and virtual-asset settlement, monitoring, reconciliation, fees, disclosures and exception handling through the live or representative system.
Treat banks, payment providers and liquidity venues as operating dependencies rather than future assumptions. Map the proposed accounts, currencies, settlement timing, fallback routes, concentration risk and the contractual basis for each provider before relying on them in the operating model.
