Georgian VASP activity includes individual portfolio management of convertible virtual assets, while collective portfolio management is excluded from that category. The first task is therefore to define the mandate and the client-specific discretion actually exercised.
We map authority to trade, custody access, investment parameters, execution, valuation, fees, conflicts, customer reporting and any separate advisory, collective-investment or financial-instrument perimeter that may arise.
Regulatory classification
The statutory VASP category concerns individual portfolio management of convertible virtual assets and excludes collective portfolio management. A pooled strategy, fund-like arrangement or product involving financial instruments should not be assumed to fall within ordinary individual VASP portfolio management.
- Individual mandate and discretion
- Custody and trading authority
- Portfolio limits and conflicts
- Valuation, fees and client reporting
Document the mandate before the investment process
The client agreement and operating model should identify the assets in scope, discretion granted, custody arrangement, trading authority, limits, prohibited transactions, fees, conflicts, reporting frequency and who can change the mandate.
Required operating evidence
Evidence should connect each mandate to account and wallet permissions, approved limits, execution records, valuation sources, fee calculations, conflict decisions, periodic reporting and exception approvals. Risk profiling can be used as a prudent control without presenting securities-style suitability terminology as a standalone VASP rule.
Principal control risks
Portfolio-management risk increases when the mandate is vague, the manager’s custody authority is unclear, pooled or collective structures are treated as individual accounts, valuation is inconsistent, fee calculations cannot be reproduced, or client-specific limits are not enforced in the trading system.
Individual management is not collective portfolio management
A structure that pools assets, issues participation interests or manages a collective strategy can require a different regulatory analysis. The commercial product should be classified before client documentation or marketing assumes that ordinary VASP portfolio management is sufficient.
Supervisory capital
Individual virtual-asset portfolio management falls within the GEL 250,000 minimum-capital category. The capital must remain eligible and available throughout operation; at least 75% of the minimum must consist of primary capital.
Scope of our engagement
Our portfolio-management work can cover individual-versus-collective perimeter analysis, mandate and authority design, custody and trading permissions, portfolio limits, valuation and fee methodology, conflicts, reporting, AML/KYT integration, application evidence and implementation review. Recommended client-risk controls are identified separately from explicit statutory requirements.
Mandate classification
Confirm individual discretionary management and identify any collective-investment, advisory or financial-instrument overlap.
Authority controls
Tie custody access, trading permissions, portfolio limits and exceptions to the mandate and accountable decision-makers.
Reporting evidence
Make valuation, fees, transactions, conflicts and client reporting reproducible from retained systems and records.
Individual portfolio-management chain
A practical sequence used to test whether contracts, systems, providers and control ownership describe the same service.
Issues to resolve before filing
Discretionary management involves authority to make and execute portfolio decisions within an agreed client mandate. Advice may leave the final decision with the client. The exact contractual authority, execution role and asset perimeter should be documented rather than inferred from the product name.
The model should identify the custodian, wallet/account ownership, signing or trading permissions and whether the manager can move assets or only place orders. Custody capability can create an additional regulated function and should be reflected in contracts and system access.
Record the agreed asset universe, discretion, concentration or exposure limits, prohibited transactions, custody arrangement, fee terms and exception process. Configure material limits in systems where practical and retain evidence of overrides and approvals.
Use documented valuation sources and timing, consistent treatment of illiquid or unavailable prices, reproducible fee calculations, transaction records and periodic statements that can be reconciled to custody and execution data.
The Georgian VASP category for portfolio management expressly excludes collective portfolio management. Pooled or fund-like structures therefore require separate legal analysis and should not be launched on the assumption that individual VASP portfolio management covers them.
