Local substance is not a single checkbox. It is the combination of accountable people, authority, premises, systems, records and documented decision-making that lets the Georgian company operate and be supervised.
Management must be able to decide and explain
Roles, delegation, conflicts, presence and reporting should be clear. Administrators need evidence of competence and reputation and must understand the business presented to the NBG.
The office is a control point
The head office should support the required records, system access, staff activity and supervisory interaction. A mailing address or meeting room used occasionally does not explain how the VASP is run.
Staffing follows the model
Customer mix, channels, hours, transaction volume, cash exposure, technology and outsourcing determine the required compliance, operations, finance, security and support capacity.
Evidence operation, not presence theatre
Maintain role descriptions, contracts, training, attendance/presence evidence, meeting and decision records, access permissions, management information and escalation outcomes.