Protect the operating value of registration through controlled updates, evidence, reporting and supervisory readiness.
The company needs an owner for regulatory changes, recurring controls, monitoring quality, management information, training, reporting, incidents and material changes to owners, administrators, services, channels, providers and systems.
Service overview
Post-registration compliance is evidenced through recurring controls, management decisions, change records, testing and timely remediation.
- Regulatory change register
- Reporting calendar and board reports
- Customer-file and alert QA
- Risk and policy refreshes
- Capital adequacy and resilience calendar
Operate the controls you presented
Registration begins supervision. Product changes, new corridors, staffing changes, incidents, provider changes and control weaknesses require documented assessment and, where applicable, regulatory action.
Management value
A live compliance calendar, useful management information, tested files and a controlled record of material changes.
Operate a live control calendar
Recurring obligations, capital adequacy, independent assurance, penetration testing, vulnerability scans, regulatory change, file and alert QA, training, incidents, product changes and board information are assigned to named owners with evidence and escalation.
A common failure
Compliance becomes a list of dates while customer-risk, monitoring backlog, overrides, provider failures and remediation quality remain invisible to management.
What you can expect from us
We begin with the live model and current evidence, agree the decisions and dependencies, then issue a written scope. You may engage us for advice and review only, for a defined implementation module, or for the complete build and regulatory coordination. The quotation caps our professional fee for the agreed assumptions and separates the GEL 5,000 official registration fee, translations, personnel, office, software, assurance and other third-party costs.
Founder decision
Agree the product perimeter, markets, counterparties and risk appetite before costly build work.
Operating evidence
Connect each claim to an accountable person, configured control, record and test result.
Launch consequence
Carry approved assumptions into filing, banking, provider onboarding and supervised operations.
Questions we address in this workstream
Ownership, administrators, services, customer markets, branches or kiosks, websites or applications, custody, providers, systems, material AML risks and operating capacity can affect the approved model. The change register should determine required approval, notification, testing and evidence before release.
The agreed scope may cover regulatory change, reporting calendars, file and alert quality assurance, risk and policy refreshes, management packs, training, material-change assessments, inspection preparation and remediation coordination. The VASP still owns decisions and obligations.
Management information should reveal customer and geographic risk, alert volume and ageing, unusual-activity decisions, sanctions events, reconciliation breaks, provider incidents, complaints, access exceptions, staff capacity, regulatory deadlines and the status of corrective action.
Keep a current evidence index, sample files and alerts, test record retrieval, rehearse system journeys and interview control owners. Findings should have root cause, owner, due date, action, retest and closure evidence rather than last-minute document production.
No. External specialists may perform defined tasks, but the company and its administrators must understand the risk, approve material decisions, oversee performance, access evidence and act on issues. Contracts should make roles and escalation transparent.
Applicable legislation and regulatory materials
- National Bank of Georgia — VASP questions and answers
- NBG Governor Order No. 94/04 — VASP registration, cancellation and regulation
- NBG Governor Order No. 133/04 — VASP fines and enforcement
- NBG Governor Order No. 207/04 — supervisory capital, operational risk and cybersecurity
- NBG Governor Order No. 204/04 — fines and enforcement amendments
