Georgia's Finansuri Monitoringis Samsakhuri (Financial Monitoring Service of Georgia) has materially tightened the country's anti-money laundering regime. Amendments to the core AML and counter-financing-of-terrorism legislation took effect on 1 January 2025, with a transitional compliance window closing on 30 June 2025. International companies operating in or through Georgia – including those relying on Georgian entities for regional treasury, correspondent banking, or holding structures – face immediate re-assessment of their compliance programmes.
Georgia's updated AML legislation introduces stricter know-your-customer requirements, expanded beneficial owner disclosure obligations, and enhanced due diligence thresholds for designated non-financial businesses and professions. All obliged entities must complete full remediation of existing customer files by 30 June 2025. Companies that fail to meet this deadline face administrative sanctions, suspension of bank account opening rights, and potential restrictions on credit facility access.
This alert identifies which business categories are affected, sets out the threshold criteria, and lists the immediate actions international companies should take before the compliance deadline.
What changed and when it took effect
Georgia's AML legislative regime is built on the country's core financial-crimes prevention legislation, which has been progressively aligned with the Financial Action Task Force recommendations. The 2025 amendments represent the most significant revision in several years.
Three substantive changes stand out. First, the definition of beneficial owner has been lowered. The ownership threshold triggering mandatory disclosure has been reduced, capturing a broader range of indirect shareholders and persons exercising effective control. Structures that previously fell below the reporting threshold may now require full beneficial owner registration.
Second, KYC (know-your-customer) requirements now apply to a wider category of transactions. Cash-equivalent transactions and certain digital-asset transfers that were previously outside the mandatory reporting perimeter are now expressly covered. The trigger amounts for enhanced due diligence have also been revised downward.
Third, the obligations of vinamdeburi pirni (obliged entities) – a defined term under Georgian financial-crimes legislation – have been extended to include a broader set of designated non-financial businesses and professions. This includes real estate intermediaries, trust and company service providers, and certain categories of accountants and legal advisers facilitating asset transfers.
The amendments took effect on 1 January 2025. Existing obliged entities have until 30 June 2025 to remediate customer files and update internal policies. New obliged entities brought within scope for the first time must achieve full compliance by the same date.
Who is affected and the threshold criteria
The following business categories are directly affected by the 2025 updates.
- Banks and licensed payment institutions conducting correspondent banking operations
- Non-bank lenders and microfinance organisations providing credit facility products
- Securities brokers and investment firms active in Georgian capital markets
- Real estate professionals facilitating transactions above the revised cash thresholds
- Legal and corporate service providers involved in company formation or asset structuring
For international companies, the risk is concentrated in two areas. First, any foreign entity that holds a Georgian subsidiary or branch is an indirect obliged entity through that subsidiary's banking relationships. Georgian banks will now request more detailed beneficial owner information at the point of bank account opening and on an ongoing basis. Delays or gaps in this information will block account maintenance and new credit facility applications.
Second, foreign companies using Georgia as a regional hub – for example, routing payments through Georgian correspondent banking channels toward CIS markets – must verify that their Georgian counterparts have completed their own remediation. Correspondent banking relationships are under increased scrutiny, and Georgian banks may restrict or terminate correspondent lines where the foreign counterpart's AML programme does not meet the updated standard.
For a broader view of banking and finance compliance obligations in Georgia, see the firm's advisory on banking and finance law in Georgia.
To assess how the updated AML rules interact with your Georgian capital markets activities, contact us at info@ferrazwhitmore.com for a preliminary compliance review.
Immediate actions before the 30 June 2025 deadline
International companies should treat the following as a priority checklist for the weeks remaining before the deadline.
1. Audit beneficial owner records. Verify that all Georgian entities in your group structure have filed accurate and current beneficial owner information with the relevant registry. Under the revised threshold, indirect shareholders who were previously below the reporting cut-off may now require formal registration. Missing or outdated entries expose the entity to administrative penalties and banking restrictions.
2. Update KYC files held by Georgian banks. Contact the relationship managers at each Georgian bank where your group holds accounts. Confirm what updated documentation is required under the new rules. Bank account opening and ongoing account maintenance will increasingly require certified beneficial owner declarations, source-of-funds documentation, and group structure charts.
3. Review correspondent banking arrangements. If your company uses Georgian correspondent banking channels, request confirmation from your Georgian bank that its own AML programme has been updated. Correspondent banking relationships that rely on a Georgian bank with deficient internal controls carry reputational and operational risk for the foreign counterpart.
4. Assess credit facility exposure. Georgian lenders are now required to apply enhanced due diligence to borrowers whose beneficial ownership structure does not meet the updated disclosure standard. Companies seeking to draw on or renew existing credit facility agreements after 30 June 2025 without compliant documentation risk delays or refusal.
5. Update internal AML policies for Georgian operations. Any internal AML or compliance manual that references Georgian regulatory thresholds should be updated to reflect the 2025 amendments. This is particularly relevant for companies subject to home-country AML obligations that extend group-wide – a failure to update subsidiary policies can create a gap that home-country regulators will identify in a group audit.
Companies engaged in Georgian capital markets transactions should also review related obligations covered in our analysis of capital markets law in Georgia.
For companies monitoring AML developments across the broader CIS region, the related alert on AML updates in Russia addresses parallel developments in a neighbouring market.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in banking and finance regulation, AML compliance, and financial-crimes prevention. We advise international companies navigating Georgia's evolving AML and KYC requirements, including entities establishing or maintaining banking relationships, correspondent banking structures, and credit facility arrangements in the Georgian market. Engaging a lawyer in Georgia with cross-border compliance experience is particularly valuable when group-wide AML policies must be reconciled with local regulatory updates. As an international law firm covering Georgia and the wider CIS region, Ferraz & Whitmore supports clients through regulatory change with practical, results-oriented counsel. To discuss your compliance position before the 30 June 2025 deadline, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.
Published: April 22, 2026 | Author: Anna Chen, Senior Associate, Asia-Pacific, Middle East & CIS
Anna Chen is a Senior Associate at Ferraz & Whitmore focusing on cross-border transactions, market entry, and dispute resolution across Asia-Pacific, Middle Eastern, and CIS jurisdictions. She supports international clients in navigating regulatory and commercial challenges in high-growth and emerging markets.