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Currency exchange licence in Georgia

Irakli

RegHub Georgia Specialist

Currency exchange is subject to a distinct regulatory regime in Georgia. National Bank of Georgia (NBG) registration is mandatory, alongside compliance with technical conditions and anti-money laundering and counter-terrorist financing (AML/CFT) requirements. These obligations apply to the activity commonly described as operating under a currency exchange licence in Georgia. The availability of staffed counters, automated cash exchange and cashless conversion attracts interest from businesses and investors. Errors during launch may result in refusal of registration, fines or subsequent cancellation of operating rights.

The discussion below examines registration and applicant eligibility, followed by the requirements for premises and equipment. It then considers transaction processing and customer disclosures. Further sections address identification and financial monitoring, together with regulatory reporting. Cashless services and exchange machines receive separate attention, as do the grounds for sanctions.

Currency exchange registration in Georgia and its legal basis

An ordinary exchange bureau does not need a banking licence. Operating rights arise when the NBG registers the business and adopts the corresponding administrative act. Although commercial terminology refers to a 'currency exchange licence', registration is the legal basis for the service.

The NBG primarily regulates this sector under its President's Order No. 167/04, which approved the registration and regulation rule for exchange bureaux. Two further sources of obligations apply:

• Organic Law of Georgia on the National Bank of Georgia;

• Georgia's AML/CFT legislation.

The regime distinguishes three operating formats:

• cash exchange at a staffed counter;

• cash exchange through an electronic machine;

• cashless conversion through accounts held with payment service providers.

Each format has technical and organisational conditions of its own. Compared with staffed cash bureaux, cashless operators must satisfy more demanding standards governing capital and management, information systems and internal controls. A bureau remains a non-bank business whatever its authorised format; it may conduct only the transactions permitted for that activity.

Currency exchange registration in Georgia is indefinite, but the permission is not an independently transferable asset. Another entrepreneur cannot acquire it by purchase or assignment. Changes in corporate structure or control remain subject to NBG requirements concerning administrators, beneficial owners and owners.

Regulatory reforms extended the regime to cashless conversion and automated cash exchange. In search terminology, 'licensing' refers to registration followed by ongoing compliance with NBG standards. Permission extends only to the formats expressly specified in the administrative act. Throughout its operating life, the bureau must observe the conditions for those formats and remains under NBG supervision.

Application documents, fees and review periods

Choosing the legal form is the first step for an entrepreneur intending to open a currency exchange bureau in Georgia. Three applicant forms qualify for cash exchange: individual entrepreneur; limited liability company (LLC); joint-stock company (JSC). The business must enter the entrepreneurial register before submitting its NBG application.

Applicants must use the prescribed form and supply their own particulars, details of administrators, significant-interest holders and beneficial owners. A register extract and documents establishing the absence of disqualifying convictions must also accompany the application.

Before approval, the applicant must have the operational infrastructure ready. The filing includes:

• a contract for specialised software;

• panic-button installation documents;

• an external CCTV installation report;

• a dimensioned floor plan;

• interior and exterior photographs;

• evidence of registration fee payment;

• documents confirming ownership of the premises or the right to use them.

Using these materials, the NBG can assess the site's compliance before transactions begin. GEL 3,000 is payable as the state registration fee. That amount excludes spending on the premises and security systems, specialised software and equipment. Notarial services and translations of foreign documents are also separate expenses.

The NBG has a statutory maximum of 60 calendar days from receiving the application to complete its review. If documents need correction, the applicant receives 30 calendar days for that purpose and the review period is suspended meanwhile. Once approval is granted, the NBG issues an individual administrative act specifying the registered name and address, the registration number and the permitted activity.

Operations must not begin before the procedure is complete. Registration may be refused for failing the eligibility criteria, having an unpaid NBG fine or a disqualifying conviction. False information and failure to correct deficiencies are further grounds for refusal.

After registration, changes to recorded particulars require notification within 10 calendar days. For branch approval, a separate NBG review has a time limit of 30 calendar days.

The legal registration charge remains GEL 3,000, while the total cost of launch depends on preparing the infrastructure. No permission is available without compliance with the technical requirements.

Owners, premises and equipment

The requirements for a currency exchange bureau in Georgia extend to both the people controlling the business and its physical premises and equipment. NBG scrutiny includes the applicant and administrators, as well as significant-interest holders and beneficial owners. A stake exceeding 10% of capital or votes constitutes a significant interest. Significant influence also brings a person within that category irrespective of the formal ownership percentage.

Convictions for serious or particularly serious crimes are disqualifying. The restriction also covers money laundering, terrorist financing and other economic offences. Criminal record certificates issued in Georgia must be dated within the preceding 15 calendar days. For certificates from another country, the permitted age extends to 60 calendar days.

Foreign documentation requires a Georgian translation, with an apostille or legalisation where the applicable procedure demands it. The operating area must be self-contained, measure at least 4 m² and remain separate from customers and other premises. It must also have an independent entrance.

The separate-entrance exception includes bureaux in shopping centres or hotels, as well as those in casinos. It also extends to airports and both railway and bus stations, together with certain comparable venues.

The following equipment is compulsory:

• equipment for detecting counterfeit banknotes;

• a computer running specialised software;

• a printer and copying equipment;

• a panic button;

• a continuously operating CCTV system.

Exterior CCTV footage must remain in secure storage for at least 30 days; the minimum for interior recordings is 180 days. If mandatory security equipment fails, the bureau must suspend customer service until the fault is rectified; transactions cannot proceed while that failure persists.

Registration does not permit continued operation with non-compliant premises or failed control systems. Operators must continue to satisfy the standards declared to the regulator. Amendments effective from 1 September 2026 strengthened certain conditions, including the retention requirements for recordings made inside the premises.

Transaction records and customer rights

For currency exchange operations in Georgia, the bureau must record each transaction in the specialised software before issuing a receipt. The receipt records the bureau's details and identifies the currencies and amounts exchanged. It also states the rate and precise transaction date and time, the customer's identification particulars and any further mandatory information.

Customer identification entries differ according to legal status:

These entries preserve the information needed to reconstruct the transaction from the records.

Currency names and the buying and selling quotes must appear on an electronic display. The typeface, character size and illumination must be uniform across those entries, with rates quoted to two decimal places.

Special notification rules apply where the buying/selling spread exceeds 3%, or where a quoted exchange rate diverges from the official lari rate by at least 3%. In either case, the bureau must supply an additional notice to the customer.

Any commission must be disclosed before completion. Counter notices must warn customers about commissions and non-standard rates, tell them to obtain a receipt and explain their right to cancel. An employee must supplement the written information with a verbal warning when a commission or a rate subject to the special rule applies.

On presentation of the receipt, a customer may cancel a standard cash transaction within 30 minutes, provided the amount does not exceed GEL 5,000 or its equivalent in foreign currency. Machine transactions have a different cancellation ceiling: GEL 3,000.

Where a banknote appears counterfeit, the bureau must prepare the prescribed document and submit the note for NBG examination. The bureau receives notification of the result within 15 working days. These requirements govern customer service for every exchange transaction.

AML/CFT controls and customer checks

Under Georgia's AML/CFT legislation, exchange bureaux are reporting financial institutions. The AML requirements for currency exchange in Georgia oblige bureaux to identify customers and verify their details. Establishing beneficial ownership and assessing risk are also required.

NBG supervision is distinct from statutory transaction reporting, for which bureaux submit reports to the FMS (Financial Monitoring Service of Georgia). Bureaux must examine unusual transactions and maintain internal controls. Reasonable suspicion requires a report, and the customer must not be informed that one has been submitted.

Full due diligence becomes mandatory above GEL 15,000 or its equivalent for an occasional transaction, including linked transactions. Customer identification is not deferred until this level is reached: bureaux must still enter the stipulated personal data on the receipt for every transaction. The separate GEL 3,000 figure relates to a particular category of occasional transfers, not a general limit on ordinary cash conversion.

Internal procedures must assign responsibility to designated staff and provide for customer assessment, examination of transactions and document retention. In business usage, 'know your customer' (KYC) denotes the procedures for establishing customer identity and verifying it. Where an organisation is the customer, the bureau must establish which natural person ultimately controls it.

A cash purchase or sale of foreign currency requires a separate report if its value exceeds GEL 50,000 or its equivalent. Submission to the FMS is due within 5 working days following the transaction. By contrast, a suspicious transaction must be reported on the day reasonable suspicion arises.

NBG registration must be followed by the required registration with the FMS. The minimum retention period for AML/CFT documentation is 5 years, counted from the end of the relationship or completion of the occasional transaction. On request from the supervisory authority, the bureau must retain the records for up to 5 additional years.

Proper retention of documents and transaction data must allow every exchange to be reconstructed. Bureaux must maintain appropriate storage and observe all AML/CFT requirements throughout their operating life.

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Cashless currency exchange in Georgia and automated services

Cashless services follow a separate regulatory regime from conventional cash counters. An LLC or JSC is eligible, provided the NBG's administrative act expressly lists cashless conversion as a permitted activity. Registration for this model requires additional corporate documentation, financial information and technical materials. 'Cashless exchange licence' is business shorthand for the resulting registration right.

The initial paid-up capital floor is GEL 500,000. Subsequent capital must equal or exceed GEL 500,000 or 15% of the preceding month's assets, whichever amount is higher. Average liquidity for each month must be at least 40%.

The bureau's director needs a higher education qualification. Minimum professional experience is 4 years in finance and 2 in management. The dossier must contain a business plan spanning at least 3 years, an IT development plan and cyber-risk assessment materials.

Settlement uses accounts with payment service providers. Incoming funds must pass from the customer's account to one held by the bureau. Converted funds must then be returned to that same customer. The declared execution period must not exceed 30 minutes.

Under the four-eyes principle, a second authorised person verifies the first employee's action as a control against operational risk. Regular information-security assessments and checks on system protection are compulsory for online providers. Infrastructure-resilience testing is an annual requirement. Only financial institutions, beneficial owners and direct owners may provide working capital funding. Public offerings of securities are exempt from this restriction. Funding from beneficial owners requires documentary confirmation.

Automated cash services have a separate operating regime. A currency exchange machine in Georgia serves individuals, including individual entrepreneurs, with a daily transaction limit of GEL 1,500 or its equivalent per customer. The machine must read the identity document and retain an electronic copy, check the banknotes and issue a receipt. CCTV monitoring is compulsory.

Each quarter's NBG submission must state the number of devices and their locations. Compared with ordinary cash counters, cashless services are more tightly controlled in finance and management, as well as information security. Registration solely for cash operations is insufficient to launch electronic exchange services.

Reporting, inspections and cancellation

Registering does not end NBG supervision. The regulator may request documents and information, conduct inspections and verify that the premises still conform to the declared conditions. A refusal to admit an inspector is among the grounds for cancellation.

Currency exchange reporting in Georgia requires a monthly return via the NBG's remote supervision portal for non-bank financial institutions. Operators have 15 calendar days after the reporting month ends to file, using separate forms for cash and cashless operations.

Each cashless bureau must publish its audited annual financial statements by 15 June of the next year. NBG checks also consider software and security arrangements, customer disclosures and internal controls. The regulator assesses each finding according to the specific offence involved.

Rather than a single minor-to-major scale, penalties follow the amounts assigned to individual offences by NBG regulation. Certain registration and operating failures, for example, attract fines of GEL 2,000. A particular repeat offence carries a fine of GEL 5,000.

Larger fines apply to more serious failures in the procedures for identification, recordkeeping and internal control. Depending on the act or omission, particular offences may attract fines of GEL 10,000–20,000.

The grounds for cancellation include:

• liquidation of the business;

• submission of false information;

• absence from the registered address;

• refusal to admit an inspector;

• breaches of NBG requirements;

• activities beyond the declared scope;

• failure to begin operations within 3 months after registration;

• cessation of operations for 3 months.

The NBG may withdraw permission for a particular activity or cancel the registration altogether. Before filing, the business should check its regulatory eligibility and confirm that its operating infrastructure is ready.

The pre-opening review should cover:

• the ownership and beneficial-ownership structure;

• administrators' particulars;

• premises' conformity with applicable requirements;

• technical equipment;

• internal controls.

Conclusion

A business seeking a currency exchange licence in Georgia must obtain NBG registration and maintain compliance with the technical, customer-service and financial-control rules. Conditions differ between staffed cash counters, machine-based operations and cashless services. Errors in the corporate structure or documentation, recordkeeping or AML/CFT procedures create a risk of fines or cancelled registration.