georgia (Georgia) Digital Banking and Commercial Banking License Application Guide

georgia (Georgia) Digital Banking and Commercial Banking License Application Guide

Subject to the Law on Commercial Banking Activities and the National Bank of Georgia (KJV) Regulated statutory financial license

The banking industry in Georgia is regulated by the National Bank (NBG)。in accordance with 2022 Amendments to the Commercial Banking Activities Act,NBG establishes "Conditional License" system。The system provides digital banks with 4 annual regulatory sandbox period,The initial minimum capital requirement is 5000 Ten thousand lari (GEL) downgraded to 500 Ten thousand lari。Licensed institutions support access to the Single Euro Payments Area (SEPA) and Open Finance (Open Finance) networks。Businesses involving crypto assets need to complete virtual asset service provider (VASP) registration at the same time。Hong Kong Huitong provides corporate establishment、Compilation of materials for executive fitness (Fit and Proper) review and legal agency services for license application。

Release time:Content has been reviewed
Feng Zhiming
Feng Zhiming Core Compliance Team
Served:Multinational Private Banking Compliance Department & offshore structuring company
permanent residence:Singapore Experience:13 Year
Expertise in compliance areas:Comoros/Vanuatu Offshore Bank、Swift system access。
personal note:Feng Zhiming - has more than 13 Years of offshore financial structuring experience。Mastering Comoros Mwali、Application for offshore banking licenses in Vanuatu and other countries,Can provide core system compliance review and Swift agent bank docking guidance for digital banks。
Familiar with the regulatory application process
Professional compliance team
Standardized compliance process
Multi-jurisdictional services

1. national bank of georgia (KJV) [Statutory Classification and Supervisory Definition of Licenses]

Statutory license type Supervisory Qualification and Business Permissions
Digital banking license
(Digital Bank License)
Legally characterized as holding"Conditional license"of commercial banks。Limited to provision of banking services through digital channels (no branch operating model),并适用开放银行及银行即服务(BaaS)架构
Regular commercial bank license
(Commercial Bank)
Provide comprehensive personal and business banking services,Covers taking deposits、grant loans、Payment settlement、Forex trading资产管理及投资银行业务
Foreign bank branch license
(Foreign Bank Branch)
foreign banks ingeorgiabranches established,Under dual jurisdiction of parent company regulator and NBG。

2. [Statutory capital requirements and sandbox mechanism] for digital banks and commercial banks

Regular commercial bank capital:The minimum statutory regulatory capital for a regular commercial bank license is 5000 Ten thousand lari (GEL)。

Digital bank initial capital:conditional licensing system,Initial minimum capital requirements for digital banks lowered to 500 Ten thousand lari (GEL)。

4Capital increase during the annual transition period:Digital bank with conditional license,Must be in 4 During the sandbox transition period, capital will be gradually replenished to 5000 Ten thousand lari。

Funding source review:The applicant must provide proof of legal sources of authorized capital and regulatory capital,Capital verification funds must be deposited into the NBG designated custody account。

3. [Legal Red Lines and Quota Requirements for Corporate Structure and Senior Executives]

Board structure:The board of directors shall consist of at least 3 composed of people,and must contain 1 local residents of Georgia。Allow foreign investment 100% holding。

Executive qualifications:Chief Executive Officer (CEO) must have 5 More than 10 years of banking management experience;Mandating a Chief Compliance Officer (CCO) to enforce AML/CFT policies,and Chief Financial Officer (CFO)。

gender diversity quota:The proportion of female representatives on the supervisory boards of commercial banks must be within 2025 Year 6 moon 1 Reached the day before 40%;The proportion of women on the board of directors is recommended to reach 33%。

suitability review (Fit & Proper):All proposed directors、Executives and major shareholders must submit criminal records and details of sources of wealth,Under NBG review。

4. Submitted to the National Bank of Georgia (KJV) [Core review document list]

Review feature categories NBG statutory requirements submission details
Executive Due Diligence Documents Provide proof of identity of directors and shareholders、No criminal record and source of funds documents,for Fit and proper review。
Business and Financial Planning Submit business plan,Includes board structure、business model、Business strategy and multi-year financial forecast statements。
Compliance and Security Architecture Submit network security architecture documents、Anti-money laundering/crackdown on fundingterrorism(AML/CFT) Policy Document。

5. Georgia Digital Bank License [Statutory Application and Approval Process]

Stage one:Name pre-review and data preparation

The bank name must contain "Bank" or "Financial"。Submit name to NBG for pre-qualification,Prepare business plan and compliance policy。

Stage 2:Capital injection and application submission

Will 500 The initial capital of RMB 10,000 is deposited into the NBG regulatory account。Submit Articles of Incorporation to NBG、Proof of funds and background information of senior executives。

Stage three:NBG due diligence

NBG’s background to shareholders、Source of funds、AML/CFT Policy、Review of IT security measures and capital adequacy。

Stage four:Issue of conditional license

A "conditional license" is issued after passing the review,Enter 4 annual regulatory sandbox period。The approval cycle is usually 6-12 months。

Stage five:Become a full-time official after the expiry of the sandbox

4 Implement additional requirements according to NBG regulations within the year and make up for them 5000 Ten thousand lari capital,Conversion to regular commercial banking license。

6. Regulatory Sandbox Business Restrictions and [Red Line for Delisting]

Personal deposit intake limits:During the sandbox period,The amount of a single personal deposit may not exceed the legal maximum insured by the Georgia Deposit Insurance Corporation。

Forced revocation mechanism:Failure to comply with license restrictions,or failed to 4 Completed within the year 5000 Marriage capital replenishment,The conditional license will be immediately revoked。

Strong supervision of crypto assets:Involving cryptocurrency business,Virtual asset service provider (VASP) registration and AML/CFT reporting obligations must be strictly fulfilled。

Annual audit submission:Licensed banks are required to submit independent financial audit reports and AML/CFT compliance reports to the NBG annually,subject to prudential supervision。

7. Georgia Bank License [Statutory Government Fees and Capital Details]

Project Category Legal amount standard (GEL)
Digital bank initial capital lowest 500 Ten thousand lari(Must be deposited into a supervision account)。
Regular bank/regular capital lowest 5000 Ten thousand lari(Digital banks need to make up within 4 years)。
Official application fee The initial license application fee payable to NBG is approx. 30 Ten thousand lari
Statutory annual maintenance fee Need to pay every year 5 Ten thousand – 20 Ten thousand lari Varying annual supervision fees (approved based on scale)。

8. 港汇通为企业提供公司注册与牌照申请全流程服务涵盖前期评估材料准备申请递交及后续合规支持

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Corporate establishment and personnel allocation

handlegeorgiaEntity registration,implement 1 Requirements for local resident directors,help achieve 40% Female supervisor quota。

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Business plan and legal drafting

Writing a network security architecture、Financial Forecasts and Business Plans,Develop NBG compliant AML/CFT operations manual。

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Official application and defense agent

Help complete 500 Verification of legal funds of Wanli,Submit information with NBG on behalf of the applicant and handle compliance defense。

9. Core Legal Questions and Answers on Georgia’s Digital Bank Regulatory License (FAQ)

What is the legal basis for a digital bank license?+

2022 The 2016 Amendment to the Commercial Banking Activities Act established the "Conditional License" system,Allow for relaxation of initial minimum capital requirements。

What are the specific requirements for statutory capital?+

Conventional commercial banks are 5000 10,000 GEL。The digital bank starts with 500 10,000 GEL,Must be in 4 To be supplemented during the transition period of 5000 10,000 GEL。

Legal limits for boards of directors and executives?+

board of directors at least 3 people,Contains 1 local residents。CEO needs 5 Years of management experience。Executives and shareholders must pass NBG’s Fit & Proper review。

Gender quota rules for supervisory boards?+

The proportion of female representatives on the supervisory boards of commercial banks must be within 2025 Year 6 moon 1 Reached the day before 40%,The Board of Directors recommends 33%。

What are the conditions for revocation of a conditional license?+

If digital banks are 4 Failure to comply with business restrictions or failure to make up as scheduled during the sandbox period 5000 Million GEL Capital,The license will be revoked。

What are the restrictions on deposit business during the sandbox period?+

Amount of single personal deposits taken by digital banks,Must not exceed the statutory maximum amount insured by the deposit insurance company。

What are the official application fees and annual fees?+

NBG initial application fee is approx. 30 10,000 GEL;After approval,Need to pay every year 5 Wanzhi 20 Annual supervision fees ranging from 10,000 GEL。

What are the core documents for submitting an application?+

Proof of legal source of authorized capital、business plan、Information about backlash between executives and shareholders,and Cybersecurity and AML/CFT Compliance Policy Documents。

Official approval process and cycle?+

After submitting the application,NBG conducts review of funding sources and compliance systems。The approval period for issuing a conditional license is usually 6-12 months。

Cross-border clearing and crypto asset compliance?+

Supports access to the EU SEPA clearing network。Crypto assets involved need to complete VASP mandatory registration simultaneously,and fulfill anti-money laundering obligations。

What agency services does Hong Kong Huitong provide?+

Covers Georgia corporate formation、Fit & Compilation of due diligence materials for Proper executives、Full-process agency for business plan writing and NBG compliance review。

10. Related licenses、Regulatory and Practical Guidance

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