Virtual-asset transfer is a recognised VASP activity when a service moves convertible virtual assets for another person. “Remittance” is a commercial description and any fiat leg must be analysed separately.
We map originator and beneficiary information, wallet types, counterparty VASPs, sanctions/KYT screening, self-hosted wallet treatment, rejected or incomplete transfers and the point at which payment-services or other financial regulation may overlap.
Regulatory classification
The transfer perimeter follows the movement of convertible virtual assets on behalf of another person. A product combining virtual-asset transfer with collection, conversion or payout of fiat can require a second analysis of the payment flow and the entities performing it.
- Originator and beneficiary data
- Counterparty VASP controls
- Self-hosted wallet treatment
- Travel Rule and sanctions readiness
Map the transfer corridor end to end
The design should identify who receives the customer instruction, which entity holds or controls assets, how counterparties are selected, what information travels with the transfer, how screening is performed and what happens when data or destination information is incomplete.
Required transfer evidence
Evidence should cover onboarding, transaction purpose and limits, wallet attribution, counterparty due diligence, Travel Rule messaging capability, sanctions and KYT decisions, exception handling, record retention and the ownership of each control.
Principal control risks
Transfer models are exposed when corridor design, wallet attribution and counterparty controls do not match the actual customer journey; when the fiat and crypto legs are documented as one undefined service; or when missing transfer information is allowed to pass without a defined decision process.
Crypto remittance can contain more than one regulated activity
A customer experience that appears to be a single remittance product may involve virtual-asset transfer, exchange, custody and a separate fiat payment leg. Each entity and step should be classified before provider contracts and customer terms are finalised.
Supervisory capital
A VASP providing transfer and/or exchange services maintains at least GEL 150,000 in supervisory capital. If the model includes another service with a higher threshold, the highest applicable amount applies. At least 75% of the minimum must consist of primary capital.
Scope of our engagement
Our transfer work can cover corridor and entity mapping, Travel Rule readiness, counterparty-VASP framework, self-hosted wallet controls, sanctions/KYT logic, fiat-flow perimeter analysis, recordkeeping, application evidence and implementation with technology providers. The work is tied to the actual countries, assets and transaction paths in scope.
Corridor classification
Identify the regulated service and any payment, exchange or custody overlap across the full transfer route.
Information controls
Define originator/beneficiary data, counterparty checks, missing-data decisions and auditable Travel Rule handling.
Operational readiness
Connect wallet screening, transaction monitoring, provider messaging and exception processes to accountable staff and systems.
Virtual-asset transfer chain
A practical sequence used to test whether contracts, systems, providers and control ownership describe the same service.
Issues to resolve before filing
The analysis focuses on whether the business transfers convertible virtual assets on behalf of another person. Internal movement of a company’s own assets is different from providing a transfer service to customers, although the surrounding exchange, custody or payment functions may still need analysis.
Define how the wallet is identified, what information is obtained, how sanctions and blockchain analytics are applied, when enhanced review is triggered and what evidence supports the decision to execute, reject or restrict the transfer.
The current Georgian transition provides for implementation by 31 December 2027. Projects should nevertheless select systems and data architecture early enough to test interoperability, counterparty handling, data quality and exception procedures before the deadline.
The procedure should define when a transfer is paused, rejected, returned or escalated; who makes the decision; how the counterparty is contacted; what sanctions/KYT review is performed; and how the decision and supporting information are retained.
Yes. If the customer journey includes collection, holding, conversion or payout of fiat, the payment leg and the entities performing it should be assessed separately. VASP registration should not be assumed to authorise a distinct fiat payment service.
