Decide whether the intended activity requires VASP registration, what overlaps arise and whether Georgia fits before costly implementation begins.
Map the customer journey, custody/control, instructions, fiat and virtual-asset movement, platform functions, counterparties, countries and revenue. Test VASP scope alongside payment, securities/investment, lending, token, data and sanctions questions.
Service overview
The assessment has to classify the actual service and customer and asset flows before the company commits to a structure, vendor stack or launch timetable.
- Classification memo
- Product and flow map
- Country and customer matrix
- Owner and group screen
Decide what the business actually does
Marketing labels are not the legal perimeter. We trace who receives the customer instruction, who controls fiat and virtual assets, where execution occurs and which entity contracts with each provider.
A credible outcome
A written scope view, red-flag register and build/no-build decision that investors, product teams and counsel can use.
The practical procedure
We run a structured product interview, draw the legal and money/asset flows, test each role against the statutory categories and identify overlaps. The output records assumptions and prohibited features so the conclusion remains usable when the product changes.
A common failure
Teams incorporate and buy vendors before deciding who holds assets, executes trades or contracts with customers. The result is a costly structure that does not match the proposed filing.
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
A conclusion may be possible where the company only deals with its own assets, or supplies pure technology without serving end customers or controlling assets or instructions. The written view records the exact facts, exclusions and product changes that would require a fresh assessment.
Customer contracting, custody or key control, order handling, execution, fees, fiat settlement, recovery rights and services supplied to third parties are usually decisive. We map the live journey instead of relying on labels such as broker, wallet or Web3 platform.
Not necessarily. If the service, custody structure, target countries or provider model is unsettled, a Regulatory Blueprint can test feasibility before incorporation and vendor commitments. The implementation sequence follows only after the founders approve the model.
It records the proposed services, parties, assets and flows; the likely VASP category; important overlaps; prohibited or high-risk features; assumptions; open questions; and a go, redesign or stop roadmap. It is a decision document, not a promise of registration.
Yes, when the intended audience and reliance are agreed in advance. We can prepare a concise operating and regulatory narrative, but it remains fact-specific and does not represent NBG confirmation, approval or an invitation to invest.
