Administration of a trading platform for convertible virtual assets is a distinct VASP activity. The platform design should therefore separate admission, order interaction, matching, execution, custody and settlement rather than describe the product as a generic exchange.
We map the operator’s role in market access, asset admission, order-book or matching logic, customer-asset control, settlement, conflicts, resilience and the controls needed to evidence an orderly operating environment.
Regulatory classification
A trading platform is not interchangeable with principal dealing or brokerage. The classification should identify whether the Georgian entity administers the venue, also executes as counterparty or agent, controls customer assets, or performs additional exchange, transfer or custody services.
- Venue and matching role
- Asset-admission governance
- Custody and settlement model
- Conflict, resilience and monitoring controls
Separate venue administration from execution and custody
The application should show what the platform itself does, which functions are performed by affiliated or third-party entities, how orders interact and settle, and whether the operator can intervene in matching, pricing, access, asset admission or customer funds.
Required operating evidence
The evidence package should cover platform rules, onboarding, asset-admission decisions, matching logic, access permissions, conflict management, system resilience, incident handling, custody and settlement responsibilities and records capable of reconstructing significant events.
Principal control risks
Platform risk increases where market rules are informal, asset admission has no accountable decision process, the operator trades against users without clear conflict controls, settlement ownership is unclear, or system monitoring cannot reconstruct anomalous activity and incidents.
Recommended market controls should be distinguished from statutory wording
For a credible trading venue we may recommend surveillance, asset-admission governance, conflict controls and event reconstruction appropriate to the platform design. These recommendations should be described as operating controls, not presented as a verbatim statutory checklist where Georgian law uses broader requirements.
Supervisory capital
A VASP administering a virtual-asset trading platform maintains at least GEL 350,000 in supervisory capital. Where the operator also provides exchange, transfer, custody or another VASP service, the highest applicable amount governs rather than adding each threshold together.
Scope of our engagement
Our trading-platform work can cover regulatory classification, venue and entity mapping, platform rules, asset-admission governance, conflict framework, custody and settlement allocation, resilience and incident controls, monitoring design, application evidence and implementation review. We distinguish legal requirements from controls recommended for the platform’s actual risk profile.
Venue role
Define whether the Georgian entity administers the market, executes trades, controls assets or combines several VASP activities.
Governance evidence
Document asset admission, access, conflicts, system permissions, incident decisions and records supporting significant market events.
Settlement model
Fix custody, clearing and settlement responsibilities so platform rules, contracts and technical architecture describe the same process.
Trading-platform operating chain
A practical sequence used to test whether contracts, systems, providers and control ownership describe the same service.
Issues to resolve before filing
A trading platform administers the venue or mechanism through which interests in convertible virtual assets interact. An exchange or broker may instead act as principal, agent or execution intermediary. A single business can combine functions, but the application should classify and evidence each one.
Use a documented decision process covering the asset’s legal and technical characteristics, issuer or project information where relevant, liquidity and custody support, sanctions/financial-crime exposure, technology risks, conflicts and the reasons for admission, restriction or removal.
The platform should retain records that allow material orders, executions, access events, system changes, exceptions and incidents to be reconstructed. Additional surveillance controls may be appropriate to the platform design and should be documented as recommended operating controls where they go beyond explicit statutory wording.
The operating model should answer this expressly. If custody or settlement is outsourced, contracts, customer disclosures, wallet/account ownership, reconciliation, incident handling and the controls retained by the platform should all reflect the allocation.
Potentially. VASP classification does not eliminate the need to assess whether a token or related arrangement falls within another financial or investment-law perimeter. Asset admission should therefore include legal classification where the token features make that relevant.
