Holding a virtual asset is not the same as providing a regulated virtual asset service. The services offered determine whether National Bank registration is relevant.
Applicable legislation: Tax Code of Georgia
Service model and the scope of registration
Assess what the platform actually does, for whose benefit it exchanges, transfers or safeguards assets, and which entity contracts with the customer. A marketing description such as “fintech platform” is not a regulatory classification.
Separate the service operator, technology supplier, contracting party and asset custodian. Compliance controls and customer due diligence must match the real workflow, not just an aspirational policy.
Relevant statutory provisionWhen National Bank registration is required
Holding a digital asset for oneself is different from supplying a virtual-asset service for another person. The National Bank defines VASPs by the actual services provided for others. Review whether the planned product offers exchange, transfer, custody or another covered service before launching; where covered, registration and compliance requirements must be addressed. Read the governing source
Registration is a precondition to offering services
Registration should be planned before launch. National Bank materials address filing requirements, the business model, management and control measures. Digital and physical delivery channels, customer arrangements, AML controls and operational security need a coherent description. The provider must also make evidence of its registration accessible to customers in accordance with the regulator’s requirements. Read the governing source
Classify the activity
Distinguish proprietary investment from exchange, custody, transfer or other virtual-asset services provided to third parties. Map real conduct to the current National Bank regulation; a label such as crypto consulting is not conclusive.
National Bank registration
If the activity is within the regulated perimeter, assemble governance and operational evidence for the appropriate registration. Registration is not equivalent to a banking licence or a guarantee of customer assets. Confirm current forms with the National Bank.
AML and client protections
Develop controls for customer identification, suspicious activity, privileged access, custody operations and transparent contractual terms, proportionate to the actual service model.
Cross-border questions
Georgian registration does not automatically authorise solicitation of customers in every other jurisdiction. Review target markets, payment partners, local licensing perimeter and sanctions constraints.
Business-model test
Compare an entity investing its own cash in bitcoin with a platform accepting customer orders and exchanging customer funds or tokens. The latter more clearly calls for a formal VASP perimeter assessment.