Proof of funds for a Georgian bank: the documents that show where your money comes from

What proof of funds does a Georgian bank ask for?

No Georgian bank publishes a fixed list. The law tells banks to understand where a client's money comes from and, for higher-risk clients, the origin of the client's wealth; each bank then decides what evidence satisfies it. In practice the request follows the money backwards: a recent statement from the account the money leaves, the document that explains how the money got into that account, and the purchase contract that explains where it is going. Advisers report requests for 3 to 12 months of statements, with 6 months common at Bank of Georgia.

This checklist is organised by where your money comes from, so you can assemble the right papers before the transfer. Why banks, notaries and the registry ask at all, and what they report, is explained in our guide to source of funds checks.

Two questions: source of funds and source of wealth

Banks ask two related questions. Source of funds is where the specific money for this payment came from, for example the sale of a flat in Warsaw last spring. Source of wealth is how you built your overall assets, for example 20 years of salary as an engineer plus an inheritance. A standard client is usually asked only the first. A client the bank treats as higher risk, because of large sums, the countries involved or a political role, is asked both.

The National Bank treats both as real duties. It has fined Bank of Georgia GEL 95,000, Terabank GEL 41,000 and Basis Bank GEL 32,800 for failing to establish clients' source of wealth or source of funds, among other breaches. A bank that asks you for more than seems reasonable is often protecting itself against exactly that.

The core file every buyer needs

• Passport, the same one used to open the account and to sign the purchase.
• The bank's know-your-customer questionnaire, completed consistently with everything below.
• Statements of the account the money is sent from, usually for the last 3 to 12 months.
• The preliminary or final purchase agreement, or a reservation document naming the property and the price.
• A one-page summary in English: amount, source, dates and the accounts the money passed through.
• For each source, the document that proves it, as listed in the next section.

The summary is the piece most buyers leave out. A compliance officer reads a clear sentence such as "USD 120,000 from the sale of my flat in Berlin in March 2026, received in my Deutsche Bank account, sent to TBC on 2 June" far faster than a stack of statements, and the same sheet serves the notary and any later bank.

Documents by source of money

Two rules run through the whole table. First, the money should move only between accounts in your own name until it reaches the seller, the developer or the escrow account. Second, every amount should be explainable: if USD 150,000 arrives and the documents cover USD 120,000, the bank will ask about the remaining USD 30,000.

Cases that need more preparation

• Gifts from parents or relatives. The bank sees money leaving someone else's account. Add the donor's passport copy, the gift letter and, for a large gift, a short note on where the donor's money came from.
• Money from your company. A payment from a company account to a personal purchase raises the question of whether it is a dividend, a salary or a loan. Show the company decision behind it and the tax treatment.
• Several small sources. Savings from many years, partly in cash, partly in deposits, are best shown as a short table with the supporting statements.
• Money that passed through a third country. Each stop needs its statement; a route that cannot be explained is the most common reason for a hold.

Crypto: what Georgian banks expect

Georgia regulates virtual asset service providers since 1 January 2023, and only providers registered with the National Bank, or banks and other licensed institutions, may offer these services; the National Bank warned again on 7 October 2025 against unregistered providers. TBC Bank's published rules say it deals only with registered providers, allows crypto transactions on personal accounts only for personal purposes, and requires proof of source of funds for the amount if the bank asks. In practice that means exchange statements showing the sale for fiat, the withdrawal to a bank account in your name and, for large sums, the history back to the purchase of the coins. Money that reaches a Georgian bank directly from a peer-to-peer trade is the hardest to explain.

Cash: why it is the weakest evidence

Cash, cheques and securities above GEL 30,000 must be declared when you enter Georgia. A declaration makes the import legal, but it shows only that the money crossed the border, not where it came from; we found no bank that treats it as proof of origin. Banks report cash deposits above GEL 50,000 to the Financial Monitoring Service. If cash is unavoidable, keep the withdrawal slips from your home bank, the customs declaration and a note linking them, and expect more questions than with a transfer. Customs confiscated undeclared cash of USD 19,100 at the Sarpi crossing in August 2025.

Language, translation and certification

No Georgian bank we checked publishes a rule on translating source-of-funds documents. Adviser reports agree that English documents are generally accepted without translation, that Bank of Georgia takes its questionnaire and statements in English, and that documents in other languages need a translation into English or Georgian. Apostilles and notarised copies are normally needed for powers of attorney and company documents rather than for ordinary evidence such as payslips or statements. Ask the bank before you order certified translations; it may save weeks and fees.

When an incoming transfer is held

A held payment is the usual sign that the file was not ready. TBC Bank's published rules say it may suspend an incoming transfer from abroad and ask, through the internet bank, for additional documents, and that the money is returned to the sender unless they are provided. The rule applies to payments from any country, with transfers from Azerbaijan, Armenia, Russia, Kazakhstan, Kyrgyzstan, Belarus and the United Arab Emirates under special focus. No bank publishes a deadline or a review time; advisers describe a few extra days at the largest banks as normal.

• Answer the request quickly and completely, with the summary and the documents together.
• Do not send the same money again to the same account while the first payment is held.
• Keep the seller or developer informed if the payment date in the contract is at risk.

Higher-risk countries, sanctions and political roles

Enhanced checks are mandatory for clients and transactions linked to the high-risk jurisdictions approved by the National Bank. The list, last amended by Order 12/04 of 21 January 2026, has 33 entries, including Iran, North Korea, Myanmar, Syria, Iraq, Pakistan, Panama, Albania, Vietnam, South Africa, Nigeria and the Cayman Islands. Russia and Belarus are not on the Georgian list, but Georgian banks apply US, EU and UK sanctions, TBC Bank prohibits transactions with Iran, and the EU added Russia to its own high-risk list from 29 January 2026, which matters if your money comes from an EU bank.

If you hold or recently held a senior public role, or are a family member or close associate of someone who does, you are a politically exposed person and should expect source-of-wealth questions and approval by the bank's management. Declare it on the questionnaire; banks check it anyway, and a missing answer looks worse than the status itself.

What the notary checks

Notaries are obliged entities under the money laundering law, which the Law on Notaries confirms; they report to the Financial Monitoring Service and are supervised by the Ministry of Justice. A notary who certifies a purchase, or holds the price on a notary deposit, applies the same customer checks as a bank for transactions above GEL 15,000 and reports deposits above GEL 50,000. In practice the notary asks for your passport, the purpose of the deal and, where the source is not obvious, the same documents you prepared for the bank, so one well-organised file serves both.

Final check before you send the money

• The sending and receiving accounts are both in your name.
• The amount matches the documents, and any difference is explained.
• The payment reference names the purpose and the property.
• The summary, statements and source documents are ready as PDF files.
• Foreign-language documents are translated or confirmed as acceptable.
• You have asked the receiving bank whether it wants the file before the money arrives.

Risks and exceptions

• Returned payments. Without documents, a held transfer can go back to the sender.
• Gaps in the chain. Cash or third-party accounts break the evidence.
• Inconsistent answers. A questionnaire that contradicts your documents triggers more checks.
• Late preparation. Translations and certificates from home can take weeks.
• Account closure. Banks may close accounts linked to sanctions without notice.

Frequently asked questions

How many months of bank statements do I need?

Usually 3 to 12; 6 months is a common request, including at Bank of Georgia.

Do my documents need an apostille?

Not usually for statements and payslips; ask the bank first.

Can family members send me the money?

Yes, with a gift letter, their passport copy and their statement.

Is crypto accepted as a source?

Only with exchange statements showing the sale and withdrawal to your account.

Can I bring cash to pay for a flat?

Legally yes, with a declaration above GEL 30,000, but it is weak evidence of origin.

What happens if I cannot prove the source?

The bank can refuse or return the payment.

Are Russian citizens treated differently?

Russia is not on Georgia's high-risk list, but banks apply sanctions and extra checks.

Does the notary ask the same questions?

Yes, notaries apply the same law for deals above GEL 15,000.

Sources

1. Law of Georgia on Facilitating the Prevention of Money Laundering and Terrorism Financing, Legislative Herald of Georgia (accessed 20 October 2026)
2. Order No 12/04 amending the list of high-risk jurisdictions, National Bank of Georgia, 21 January 2026 (accessed 20 October 2026)
3. AML/CFT supervision and sanctions on banks, National Bank of Georgia (accessed 20 October 2026)
4. Warning on unregistered virtual asset service providers, National Bank of Georgia, 7 October 2025 (accessed 20 October 2026)
5. Virtual asset transactions, TBC Bank (accessed 20 October 2026)
6. Transactions with sanctioned countries and incoming transfers, TBC Bank, 2024 (accessed 20 October 2026)
7. Terms and conditions, Credo Bank, 1 July 2024 (accessed 20 October 2026)
8. Law of Georgia on Notaries, Legislative Herald of Georgia (accessed 20 October 2026)
9. What we must know when crossing the customs borders of Georgia, Revenue Service of Georgia (accessed 20 October 2026)
10. Customs seizes undeclared cash at Sarpi, Georgia Today, 29 August 2025 (accessed 20 October 2026)
11. Commission Delegated Regulation (EU) 2026/46 on high-risk third countries, EUR-Lex (accessed 20 October 2026)
12. Why Georgian banks refuse accounts to foreign nationals, PB Services, 8 October 2025 (accessed 20 October 2026)
13. Opening a bank card in Georgia, T-Zhurnal, 18 May 2026 (accessed 20 October 2026)
14. Money transfers to Georgia, Madloba, October 2026 (accessed 20 October 2026)

Change log

• 20 October 2026 - Checklist published from the money laundering law, the National Bank's high-risk list of January 2026, bank terms and adviser reports on what banks ask for.