8
Supervisory bodies
2
Entry routes: licence or registration
9
Sectors covered
1
FIU / FMS
02The regulatory landscape
02
Who supervises what in Georgia
Georgia splits financial-crime supervision across several bodies, not one desk. Some activity is licensed, some only registered, some sits in a sector with no dedicated regulator. Which body holds your file, whether you are licensed or registered, and what it will actually ask for: that is the first thing we map.
- NBG, the National Bank: VASPs, payments and MSB, banks and financial institutions, investment funds.
- MoF, the Ministry of Finance: dealing in precious stones and metals.
- Revenue Service: gaming and gambling, and export permits.
- NAPR / MoJ, the Bar and SARAS: real estate gatekeeping and the DNFBP professions.
- MoD: defence and dual-use export control.
- FMS: the national FIU that receives your reporting.
VASP & crypto
NBG Maintains the register of virtual asset service providers. VASPs enter through NBG registration, not a bank-style licence, and a register entry buys no relief from the full AML obligation. Public VASP register at nbg.gov.ge.
Payments & MSB
NBG Supervises payment and money-services businesses under a licensing regime. Supervisory information at nbg.gov.ge.
Banks & FIs
NBG Licenses and oversees commercial banks and other financial institutions. List of licensed commercial banks at nbg.gov.ge.
Funds & CSP
NBG Supervises investment funds and fund administration. Investment-funds supervision page at nbg.gov.ge.
Gold & DPMS
MoF Carries AML supervision for persons trading in precious stones and metals, the closest accountable category for gold, bullion and high-value dealing.
Gaming
Revenue Service A legal entity of public law under the Ministry of Finance. Supervises gaming and gambling operators, and issues permits that sit alongside export-control decisions.
Real estate & DNFBP
NAPR / MoJBarSARAS No single dedicated regulator. Property gatekeeping runs through the National Agency of Public Registry (NAPR) under the Ministry of Justice, at napr.gov.ge. Professional AML is split: MoJ for notaries, the Georgian Bar Association for lawyers, SARAS for accountants and auditors.
Defence & dual-use
MoDRevenue Service Exports controlled by the Ministry of Defence through its Standing Committee on Military-Technical Matters. Permits issued by the Revenue Service.
Art & high-value
MoFFMS Not separately enumerated as an accountable category. Closest accountable footing is persons trading in precious stones or metals, AML-supervised by the Ministry of Finance. Do not assume you fall outside scope: map to the nearest enumerated category and build to it.
Across every accountable sector, the Financial Monitoring Service of Georgia (FMS) is the national FIU: the body that receives your suspicious-transaction and threshold reporting. We ground every reference in the current published framework, and never assert a deadline, penalty or statute number without a source.
03Who operates here, and what they build
Licensed or only registered, every operator here is an accountable person under Georgian AML law and must build and run the same core, sized to its risk. A register entry buys no relief. Who Georgia draws:
- Virtual asset firms on the NBG registration regime.
- Payment and e-money businesses on the Caucasus corridor.
- Banks and microfinance institutions.
- Fund and administration vehicles.
- Gaming operators, bullion dealers and property intermediaries.
01A documented business-wide and customer risk assessment that a supervisor can follow.
02Customer due diligence, enhanced due diligence and beneficial-ownership identification that actually runs, not just a policy PDF.
03Sanctions and PEP screening calibrated to Georgia's exposure and its transit position between Europe, Russia and the wider Caucasus.
04Transaction monitoring with tuned rules and an alert-to-report workflow that reaches the FMS.
05A named, competent MLRO and a live reporting line to the Financial Monitoring Service of Georgia.
06Suspicious-transaction and threshold reporting, record-keeping and staff training that hold up under inspection.
07For crypto and payments specifically: Travel Rule readiness, wallet attribution and counterparty controls.
The regulator does not inspect your licence. It inspects what you built behind it.
04By sector here
Every sector in Georgia, served in full
We work every regulated and accountable sector here with equal weight. No single industry is our flagship. Below: where each sector sits, the body that supervises it, whether the route is a licence or registration, and the way in.
VASP & cryptoNBG VASP register, registration route. Programme build for registration, Travel Rule readiness, wallet and counterparty controls, ongoing monitoring.
Payments & MSBNBG, licensed. Licensing-grade AML build, corridor-risk monitoring, screening and reporting for payment and money-services businesses.
Banks & FIsNBG, licensed. Full-scope programme build, remediation and independent audit for banks and financial institutions.
Funds & CSPNBG investment-funds supervision. AML frameworks for funds, fund administration and corporate-service providers.
Gold & DPMSMoF-supervised dealing in precious stones and metals. AML programmes, sourcing and counterparty integrity checks.
GamingRevenue Service supervised. CDD, monitoring and FMS reporting for gaming and gambling operators.
Real estate & DNFBPNo dedicated regulator. Gatekeeping via NAPR under the MoJ; professional AML split across MoJ, the Georgian Bar Association and SARAS. Source-of-funds and gatekeeper controls.
Defence & dual-useMoD Standing Committee on Military-Technical Matters, permits via the Revenue Service. Export-control, end-use and sanctions screening.
Art & high-valueNo dedicated regulator; closest accountable footing is precious-stones-and-metals dealing under the MoF, with the FMS as FIU. Integrity due diligence and high-value transaction controls.
05The five service lines, in this market
01
Licensing and new-regime programme build. The compliance programme that sits behind an NBG licence or VASP registration, a Revenue Service permit or an MoF-supervised registration, built to the standard that supervisor inspects to, ready before the first audit.
02
Remediation. Post-finding or post-enforcement rebuild of a Georgian programme, on a fixed scope, with the evidence a supervisor will ask for and a defensible closure trail.
03
Outsourced and bridge MLRO plus managed FIU function. A senior MLRO and a working reporting line into the Financial Monitoring Service of Georgia while you recruit, scale, or stabilise after a departure.
04
Independent AML audit. The independent review a Georgian supervisor expects, run by a practitioner who did not build the thing being reviewed.
05
Sanctions, export-control and integrity due diligence. Counterparty, corridor, beneficial-owner and Travel Rule work, including controls for dual-use exposure under the MoD export-control regime.
06The operator-side value
We are the reviewer, not the seller
Lawyers file the application. Vendors sell the screening tool. We do neither. Black Sea sits on your side of the table, builds the programme the NBG, MoF, Revenue Service or FMS expects, and can run it until your own function stands alone. In the region we work alongside our signed partner, a licensed local firm.
Independent
No software, no commissions, no conflict. Nothing we recommend is a product we are paid to place.
Senior-only
Practitioners, not a junior bench. CAMS / ICA credentialed. The people who scope your programme are the people who build it.
Fixed scope
A costed plan within 48 hours. No hourly billing. You know what you are buying before you commit.
Build & run
From programme design to a bridge MLRO and a managed FIU function, until your own function stands alone.
Briefing seriesCurrent and datedAn ongoing, dated financial-crime briefing feed, read across the frontier and Gulf markets we cover.Insights →
Local partnersLocal legal standingLicensed local law-firm and compliance partners in our markets.Partners →
Press pickupKazakh pressIndependent coverage of our work and commentary, on merit rather than placement.The record →
Map your Georgian programme against the regulator.
Tell us where you sit, which body supervises you, and whether you are licensed or registered. Fixed-scope read and a costed plan within 48 hours.