Anti-money laundering and know-your-customer policy

This policy in short

Every property purchase in Georgia passes through institutions that the law obliges to check who you are and where your money comes from: the bank that sends or receives the payment, the notary who certifies a document, and the Public Registry that records the transfer. AVI Estates is a real estate agency and advisory firm. Under the current text of Georgia's anti-money-laundering law, real estate agents are not among the obliged entities, so the statutory duties described below fall on those institutions and not on us. We still apply our own know-your-customer checks to every client, for three reasons: a purchase that a bank stops halfway harms the client most; we will not lend our name to a deal we cannot explain; and the law may be extended to agents, as international evaluators have recommended. This page sets out what the law requires of others, what we ask of you, and when we decline to act.

The law that applies

The governing act is Law No 5226-Is of 30 October 2019 on facilitating the prevention of money laundering and terrorism financing, referred to below as the AML law. We checked it against the Georgian consolidated text dated 1 April 2026 on the Legislative Herald of Georgia (matsne.gov.ge) and against the English translation published there. The points that matter for a property buyer are these:

• Article 3(1) lists the obliged entities: financial institutions such as commercial banks, microfinance organisations, payment service providers, currency exchange offices, insurers, leasing and brokerage companies and virtual asset service providers; persons in non-financial activities, namely lawyers and law firms, notaries, certified accountants and accounting firms, auditors, lottery and gambling organisers, and dealers in precious stones or metals; and two public bodies, the National Agency of Public Registry and the Revenue Service.
• Article 3(2) brings lawyers and notaries under the law only for certain client work, and the first item on that list is buying, selling or gifting real estate.
• Article 10 sets the preventive measures: identify and verify the client from a reliable and independent source, identify the beneficial owner, establish the purpose and intended nature of the relationship, and monitor it. A person acting for the client is identified too, and the obliged entity obtains a duly certified document proving the authority to represent.
• Article 11(1) says when these measures apply: when a business relationship begins; for a single transaction, or linked transactions, above GEL 15,000 or the equivalent; for a one-off transfer of money above GEL 3,000; and whenever the identification data already obtained are in doubt.
• Article 13(2) defines the beneficial owner of a company as a natural person holding, directly or indirectly, 25% or more of its shares or voting rights, or otherwise exercising ultimate control.
• Article 27(1) requires obliged entities to keep identification records for five years after the relationship ends or the single transaction is made.

Real estate agents and brokers do not appear in the list in Article 3. MONEYVAL, the Council of Europe's anti-money-laundering evaluation body, made the same observation in its second enhanced follow-up report on Georgia, released on 7 May 2024: it found no AML requirements for real estate agents and rated this a moderate shortcoming. We publish this not as a loophole but as a fact a client should know, because it explains why the questions about your money will come mainly from your bank and your notary.

Who checks you, and when, in a typical purchase

Institution	When it checks you	What it may ask for
Your bank in Georgia	When you open an account, and on transfers that pass its thresholds or look unusual	Passport, address, purpose of the account, expected turnover, the origin of the money for larger or higher-risk payments
The bank sending your money from abroad	Under the rules of its own country	The purpose of the transfer and supporting documents, often the preliminary agreement
The seller's or developer's bank	When the purchase price arrives	Sometimes the contract that explains the payment, requested from the account holder
Notary	When certifying a sale, a gift or a power of attorney connected with real estate	Identity documents of each party and of any representative, and questions about the transaction
Lawyer	When acting for a client in buying or selling real estate	The same identification as a notary, and the beneficial owner if the buyer is a company
National Agency of Public Registry	On registration of the transfer	Identification of the applicant; under Article 25(4) it reports registrations of rights to immovable property to the Financial Monitoring Service in cases the Service defines
Revenue Service (customs)	When cash or securities cross the border	A declaration for amounts above GEL 30,000 or the equivalent; it reports such movements to the Financial Monitoring Service under Article 25(5)

The Financial Monitoring Service of Georgia is the authority that receives reports of suspicious transactions from all of these bodies. Because a property price almost always exceeds GEL 15,000, you should expect identification and questions on every purchase, whoever the seller is and however the deal is structured.

What we ask of every client

Before we sign a service agreement, and before we take any step on your behalf, we ask for the following. The list mirrors what the obliged entities will ask later, so the work is done once and done early.

1. Identity. A copy of a valid passport, compared with the person we speak to on a video call or in the office. For a company, its registration documents and the identity of every beneficial owner, using the 25% test of Article 13 as our reference.
2. Representation. If someone acts for you, their identity and a notarised power of attorney, apostilled or legalised where needed and translated into Georgian, as described in our guide to powers of attorney.
3. Purpose. Why you are buying: to live in, to let, for a residence permit, as an investment. The answer shapes our advice anyway, and a bank will ask the same question.
4. Payment route. Which account the purchase price will come from, in whose name, and through which countries it will pass. The payer should be you or your company.
5. Origin of the money, in general terms. Salary, savings, sale of a business or a property, inheritance, investment income. We do not audit your finances; we ask so that the documents your bank will want are ready before the transfer, not after it has been held.
6. Public functions. Whether you, a family member or a close associate hold or recently held a senior public or political position. Article 21 of the law calls such a person "politically active" and requires banks to apply stronger measures; telling us early avoids a stalled transfer.
7. Sanctions. We check the names of clients and of any company buyer's owners against the consolidated sanctions list of the United Nations Security Council, which Georgia enforces under Article 41 of the law, and against other lists that the bank handling the payment applies.

How money moves, and what never passes through us

Our policy is that the purchase price never passes through AVI Estates. It goes from the buyer's bank account to the seller's or developer's account, or into a bank escrow or a notary's deposit account, by a route set out in the contract and described in our guide to safe payment. Our own fees are invoiced to the client and paid by bank transfer under the written agreement. We do not accept cash for purchase prices, we do not hold deposits on a client's behalf in our own account, and we do not pay a seller on a buyer's instructions.

When we decline or stop working

We do not take on, or we stop, a matter in any of these situations. We do not have to explain the reason in each case, and we return any part of an advance fee for work not done under the terms of the agreement.

• A client will not identify themselves, their representative or the person who really owns the buying company.
• The money is to come from a third party whose connection with the buyer is not explained, or from an account in a name other than the buyer's.
• We are asked to split a payment into smaller amounts, or to record a price below the one actually paid, so as to stay under a threshold or reduce a tax.
• The plan involves carrying large amounts of cash into Georgia without declaring them at the border.
• A price is far from the market for no reason anyone will give, or a buyer is unconcerned about the value of what they are paying for.
• A party appears on a sanctions list, or acts for someone who does.
• A company structure has layers in several jurisdictions with no business reason that its owners will state.
• We are pressed to hurry precisely at the point where a document or an answer is missing.

The law calls a complex or unusually large transaction without a clear economic or legal purpose an "extraordinary transaction" in Article 20 and obliges banks and other obliged entities to examine it. Several of the situations above are exactly what makes a bank examine a payment, which is another reason we raise them first.

Reporting suspicions, and what we cannot tell you

Under the current text, an agency like ours has no statutory duty to file suspicious transaction reports with the Financial Monitoring Service, because the duty in Article 25 rests on obliged entities. If we have reason to believe that a transaction is connected with a crime, we stop working on it and may inform the competent authorities, as any person in Georgia can. Obliged entities face a further rule in Article 28: they may not tell a client that a transaction is being examined or that a report has been filed. In practice this means that a bank may delay or refuse a payment without giving a reason, and we may not be able to find out why for you. The way to reduce that risk is to give the bank the documents it is likely to ask for before you send the money.

The records we keep

We keep copies of identification documents, the answers to the questions above and the record of our sanctions checks for five years after the end of the service. That period follows the standard Article 27 sets for obliged entities, so that if a bank, a notary or an authority asks us later about a client we acted for, the information still exists. The records are held under our privacy policy: they are used for this purpose only, shared only where the law requires or the client agrees, and deleted when the period ends. Our privacy policy lists anti-money-laundering checks among the purposes of processing client data; for an agency that is not an obliged entity, the basis for these checks is our legitimate interest in not facilitating crime and in protecting the client's transaction, together with the client's agreement in the service contract.

How to prepare as a buyer

Most delays we see are not refusals; they are payments held while a bank waits for a document. You can avoid most of them by assembling a short file before the first transfer:

• Passport, and for a company the extract from its register with the shareholders and directors.
• The preliminary agreement or the sale contract, so the purpose of the payment is evident.
• Evidence of where the money comes from: payslips or an employment contract, a contract for the sale of another property, a dividend statement, an inheritance certificate, or a bank statement showing savings built up over time.
• A bank statement that shows the path of the money from that origin to the account that will pay.
• Translations of the key documents into English or Georgian if they are in another language.

Pay from an account in your own name, in one route you can document, and avoid carrying cash. If you do bring cash, Georgian customs require a declaration above GEL 30,000 or its equivalent, and undeclared sums can be confiscated. Our guides on transferring money to Georgia and opening a bank account as a non-resident cover the practical steps.

Sellers, landlords and developers

When we act for a seller or a landlord, or show a developer's units to a buyer, we identify the owner from the Public Registry extract and the owner's passport, and the representative from a power of attorney. Sale proceeds should be paid to an account in the registered owner's name. We do not arrange payments to accounts of people who are not party to the contract, and we tell a buyer at once if a seller asks for that. A developer's contract should name the developer's own account for each instalment, as our guide to the developer contract explains.

Who is responsible, and how this policy is kept current

The lead adviser is responsible for applying this policy, deciding on a client who raises a concern, and keeping the records. The policy is reviewed at least once a year and whenever the law, a supervisory instruction or a relevant international evaluation changes; each review is dated in the change log below. If Georgia adds real estate agents to the list of obliged entities, this page will be rewritten to describe the statutory duties that then apply to us, including registration, reporting and an internal compliance system under Article 29.

Frequently asked questions

Is a real estate agency in Georgia an obliged entity under the AML law?

Not under the current text. Article 3 of the law lists banks and other financial institutions, lawyers, notaries, accountants, auditors, gambling organisers, dealers in precious metals, the Public Registry and the Revenue Service, but not real estate agents. Our lawyer is reviewing this reading.

Why do you ask where my money comes from if the law does not require it?

Because your bank and the notary will ask, and a payment held while a bank waits for documents can delay or endanger a purchase. Preparing the answers early protects your transaction.

Do I have to declare cash at the Georgian border?

Yes, cash and securities above GEL 30,000 or the equivalent must be declared to customs, and undeclared sums can be confiscated. We advise against paying for property in cash.

Does AVI Estates hold my purchase money?

Our policy is that it does not. The price goes from your bank to the seller's or developer's account, or through a bank escrow or a notary's deposit account.

Change log

• 13 October 2026 - Draft published for lawyer review, checked against the Georgian consolidated text of 1 April 2026.