A Georgian VASP cannot be operated credibly through names on a company extract. The National Bank expects identifiable administrators with suitable reputation and competence, real authority, access to the operating system and a presence structure that allows supervision in Georgia.
Who counts as management?
The legal and practical analysis starts with the administrators and the people who actually direct the VASP. Titles alone do not allocate responsibility. The application should explain who approves customers and products, who controls AML escalation, who oversees technology and providers, who owns finance and reporting, and who can take urgent decisions in Georgia.
Fit-and-proper is an evidence exercise
Administrators should be prepared to evidence identity, education, professional history, relevant competence, business reputation, criminal-record status, conflicts, solvency and time commitment as required by the applicable forms and circumstances. Foreign records often need recent issuance, apostille or legalisation and certified Georgian translation.
The narrative matters as much as the attachments. A director’s experience should make sense for the proposed exchange, custody, transfer, platform or stablecoin model. Gaps can sometimes be managed through a balanced board, specialist appointments, training and clearly divided authority; they should not be hidden behind generic CV language.
Presence of an authorised representative
The registration rule requires at least one person authorised to represent the VASP to be present in Georgia for at least 14 calendar days in each month. The presence plan should identify the person, authority, working location, system access, cover arrangements and evidence. It should also work during leave, illness, incident response and regulatory meetings.
The sole shareholder/director point
Where the sole shareholder is also a director, the rule requires at least two directors. Founder-led teams should resolve this early because the second appointment affects governance, signatures, evidence, employment or service terms, access rights and the organisation plan.
Local substance is broader than one director
A high-volume retail exchange, cash network or custody operation may need meaningful local compliance, operations, finance, security and customer-support capacity. A lower-volume institutional model may be structured differently. The right answer follows the hours, customers, risks, transaction volumes, outsourcing and incident duties—not a fixed staffing package.
What we build with management
- Governance and reserved-matters map.
- Role profiles, competence criteria and candidate evidence checklist.
- Fit-and-proper data room with translation and validity controls.
- Presence, delegation and absence-cover plan.
- Board, management and compliance reporting calendar.
- System access and decision-evidence matrix.
- Interview and system-demonstration rehearsal.
Why nominee language is dangerous
A director who lacks time, competence, authority or access creates risk for registration, banking and later supervision. CryptoLicense.ge can support role design, search coordination, screening and onboarding, but we do not market a name-only nominee arrangement or imply that an external adviser takes the VASP’s accountability.
Official materials used for this guide
These links support the editorial baseline; the explanation above is written for founders and operators. Current consolidated legislation and later official instruments take priority.