Overview of Georgian EMI Licensing
Georgia offers electronic money institution licensing under the oversight of the National Bank of Georgia (NBG). While not an EU member state, Georgia has developed its financial services regulatory framework to accommodate modern payment technologies and electronic money operations.
The Georgian licensing regime provides a pathway for entrepreneurs seeking to establish payment services and electronic money operations in the Caucasus region, with the NBG serving as the primary regulatory authority.
Regulatory Framework
Georgian electronic money regulation derives from domestic legislation:
Law on Payment Services and Payment Systems: The primary legislation governing payment services and electronic money activities in Georgia.
National Bank of Georgia Regulations: NBG oversight and regulations establishing operational standards for licensed institutions.
Anti-Money Laundering Legislation: Georgian AML requirements establishing customer due diligence and suspicious activity reporting obligations.
Licensing Requirements
Georgian law mandates proper licensing for businesses engaged in:
Electronic Money Activities
- •Issuance of electronic money
- •Redemption of electronic money
- •Distribution through authorized channels
Payment Services
- •Operation of payment accounts
- •Payment transaction execution
- •Money remittance services
- •Payment processing
Authorization Process
Pre-Application Phase
- •Business model development
- •Corporate establishment in Georgia
- •Capital arrangement
- •Compliance framework development
Application Submission
- •Complete documentation package to NBG
- •Application fee payment
- •Formal acknowledgment
Regulatory Review
NBG evaluates:
- •Business plan viability
- •Capital adequacy
- •Management fitness and propriety
- •Governance and compliance frameworks
- •Operational readiness
Decision
- •License granted (with or without conditions)
- •Or refusal with stated reasons
Post-Authorization
- •Implementation of operational systems
- •Banking relationship establishment
- •Supervised commencement of activities
Documentation Requirements
EMI applications require comprehensive documentation:
Corporate Documents
- •Company registration documents
- •Articles of association
- •Shareholder structure and beneficial ownership
- •Management appointments
Business Planning
- •Detailed business plan
- •Financial projections
- •Description of proposed services
- •Risk assessment
Compliance Documentation
- •AML/CFT policies and procedures
- •Risk management framework
- •Internal control mechanisms
- •IT security measures
Personnel Documentation
- •Management CVs and qualifications
- •Fit and proper declarations
- •Organizational structure
Compliance Framework
Anti-Money Laundering
Licensed Georgian EMIs must implement:
- •Customer identification and verification
- •Transaction monitoring
- •Suspicious activity reporting
- •Record keeping
Operational Standards
- •Adequate technical infrastructure
- •Security controls
- •Business continuity measures
Advantages of Georgian Licensing
Regional Position
- •Gateway to Caucasus markets
- •Strategic location between Europe and Asia
Business Environment
- •Developing FinTech ecosystem
- •Competitive operating costs
- •Business-friendly regulatory approach
Growth Potential
- •Emerging market opportunities
- •Increasing digital payment adoption
Practical Considerations
Professional Support
Most applicants engage:
- •Georgian legal counsel familiar with NBG requirements
- •Compliance specialists
- •Local accounting support
Language
Georgian language requirements may apply for certain regulatory submissions.
Banking Relationships
Establishing corporate banking facilities with Georgian institutions requires standard due diligence procedures.
Conclusion
Georgian EMI licensing provides a pathway to payment services operations in the Caucasus region under NBG supervision. While the regulatory framework continues to develop, Georgia offers opportunities for businesses seeking to establish electronic money operations in emerging markets.
Success requires thorough preparation, including robust compliance frameworks, qualified management, and understanding of Georgian regulatory requirements. Companies should engage appropriate local professional support throughout the licensing process.