Why does everyone ask where my money comes from?
Because Georgian law makes them. Georgia's anti-money-laundering law of 30 October 2019, in its version consolidated on 1 April 2026, turns banks, notaries, lawyers, the Public Registry and a long list of other businesses into "obliged entities". Each of them must know who its client is, understand what the money is for and, where the risk calls for it, establish where the money and the client's wealth came from. A buyer of a flat meets these duties at almost every step, because a property price is far above the amounts at which the checks begin.
The question is routine and is put to Georgian and foreign buyers alike. This explainer sets out who asks and on what legal basis, when a check becomes deeper, what is reported to the Financial Monitoring Service, how cash and crypto fit in, and how to prepare so that a payment is not held up. It covers the law; it is not a list of what any particular bank will accept.
Who asks, and why
| Party | Obliged entity? | Supervisor |
|---|---|---|
| Georgian bank | Yes, for every client | National Bank of Georgia |
| Notary | Yes, when the service concerns buying, selling or gifting real estate and similar services | Ministry of Justice |
| Public Registry | Yes, when it registers ownership on a sale or a gift | Ministry of Justice |
| Lawyer | Yes, for property deals and managing client money | Georgian Bar Association |
| Real estate agent | No, agents are not on the list | None under this law |
Agents are the gap. The law does not list them, and MONEYVAL, the Council of Europe's evaluation body, has repeatedly recorded that Georgian real estate agents have no anti-money-laundering requirements or supervision. When an agent asks about your money, it is either the agent's own policy or a request passed on from a bank or developer. Developers are not on the list either, but your payment reaches them through a bank, and the bank is.
When the checks start
The law requires customer due diligence in four situations: when a business relationship begins, such as opening an account; for a one-off transaction, or a set of linked ones, above GEL 15,000 or the equivalent in foreign currency; for a one-off wire transfer above GEL 3,000; and whenever money laundering or terrorist financing is suspected, whatever the amount. The law defines linked transactions so that splitting a payment into smaller parts does not avoid the threshold. For a one-off transaction through a crypto service provider the threshold is USD 1,000, EUR 1,000 or GEL 3,000. In practice every flat purchase crosses the GEL 15,000 line, so you should expect the checks on every deal.
What a standard check covers
- Identity. Identifying you and verifying it against a reliable, independent source, usually your passport.
- Beneficial owner. If you buy through a company, the natural persons behind it: anyone holding 25% or more of the shares or votes, or otherwise in ultimate control.
- Purpose. What the relationship or the transaction is for, for example buying a named flat.
- Expected activity. Your line of business and the expected nature, volume and frequency of your transactions.
- Monitoring. Checking later transactions against that picture and, where necessary, checking the origin of your property, funds and virtual assets.
The checks must be done before the transaction or the start of the relationship, and repeated periodically afterwards. A bank that asks for an updated questionnaire a year after you opened your account is following this rule, not singling you out.
When the questions go deeper
Enhanced due diligence is where "source of funds" and "source of wealth" become explicit legal duties. For a client assessed as high-risk, the obliged entity must collect more information about the client's property and activity and about the purpose of past and expected transactions, obtain management approval, take reasonable measures to establish the origin of the client's property, funds and convertible virtual assets, and monitor the relationship more closely.
- High-risk jurisdictions. The National Bank approves a list of high-risk jurisdictions. Clients registered or actually resident there, and transactions through financial institutions located there, receive enhanced checks. There is an exemption: for a natural person resident in such a jurisdiction, enhanced checks are not mandatory if the person is a Georgian citizen or a foreigner with a Georgian residence permit.
- Unusual transactions. A complex or unusually large transaction, or an unusual pattern, with no apparent economic or lawful purpose must be examined, and the entity must be able to justify that examination to its supervisor.
- Politically exposed persons. Heads of state and government, ministers, members of parliament, senior judges, central bank board members, ambassadors and heads of state-owned companies, among others, together with their family members and close associates. For them the origin of property and funds must be established and management must approve, and the measures continue after the person leaves office.
To be added by the team: the partner lawyer to confirm the current list of high-risk jurisdictions approved by the National Bank and whether it includes countries our readers commonly come from.
What is reported, and to whom
The Financial Monitoring Service of Georgia receives two kinds of report. The first is a suspicious transaction report, which every obliged entity must file on the same day the suspicion arises, whatever the amount, including for an attempted transaction. The second is a threshold report, set by the Service's own rules, which is filed automatically and says nothing about suspicion.
| Who reports | What | Threshold |
|---|---|---|
| Banks | Cash paid into an account; cash currency exchange | Above GEL 50,000 |
| Banks | Transfers to or from a high-risk jurisdiction | Above GEL 50,000 |
| Notaries | Money or securities placed on the notary's deposit account in a property deal | Above GEL 50,000 |
| Public Registry | Sales of real property | Above GEL 300,000 |
| Public Registry | Sales or gifts with a sanctioned party, a party in a high-risk jurisdiction, or a price far from the market | Any amount |
Notaries and the registry have 5 working days for their threshold reports. When the registry spots a suspicious deal before registration, it reports first and waits: if the Service does not suspend the transaction within 24 hours, registration continues. The Service can order any obliged entity to suspend a transaction for up to 72 hours, not counting weekends and holidays. Records of checks, transactions and reports are kept for 5 years, and the Service or the supervisor can extend that by up to 5 more.
To be added by the team: the partner lawyer to confirm that the registry's GEL 300,000 report and the other registry thresholds are unchanged in the current consolidated text of the FMS rules.
Why nobody tells you what is happening
An obliged entity, its managers and its staff may not tell the client, or anyone else, that an unusual transaction is being examined, that a report has been or will be filed, or that the Service has suspended a payment. A bank that reports in good faith is protected from liability for breaching confidentiality. This is why a payment can sit for days with only a general answer from the bank, and why asking your agent or lawyer to "find out what the problem is" rarely produces a reason. The practical lesson is to answer the questions before they are asked.
If the check cannot be completed
The law is blunt: an obliged entity that cannot complete its due diligence may not start or continue the business relationship, and may not carry out the one-off transaction. It must also consider whether the situation itself calls for a suspicious transaction report. For a buyer this can mean an account application refused, a transfer returned to the sending bank, or a notary who will not certify the deal until the questions are answered. None of these needs to be explained to you, and none can be fixed by insisting.
Paying in cash
We found no general legal cap on cash payments in Georgia and no rule that a property price must be paid through a bank. Cash is caught by thresholds instead: banks report cash paid into accounts and cash exchanges above GEL 50,000, notaries report deposits above GEL 50,000, and cash or securities above GEL 30,000 carried across the border must be declared, with the Revenue Service passing the details to the Financial Monitoring Service within 5 working days. A further point matters for prices in dollars: under the Organic Law on the National Bank, the lari is the only legal tender in Georgia, except in cases the law or the National Bank sets.
A bank transfer from an account in your name is the payment that best answers the question "where did this money come from", because the trail is the evidence. Cash removes the trail and moves the question to the next bank that sees the money.
To be added by the team: the partner lawyer to confirm whether a price agreed in dollars may lawfully be paid in dollar cash between individuals.
Crypto as a source of funds
Georgia regulates virtual assets through the National Bank. Since 1 January 2023 virtual asset service providers must register with it, under registration rules approved on 13 June 2023, and since 1 July 2023 commercial banks may provide virtual asset services. Payments in virtual assets themselves are prohibited except where a National Bank act allows them. Service providers are obliged entities: they must pass originator and beneficiary information with each transfer, and the enhanced checks expressly cover the origin of convertible virtual assets.
For a buyer whose savings are in crypto, the realistic route is conversion through a registered provider or a bank, with exchange statements that show when and how the assets were acquired and sold. We found no published bank policy on accepting crypto-origin money for a property purchase.
To be added by the team: the partner lawyer to confirm which National Bank act, if any, allows payment for real estate in virtual assets, and the safest documented route from crypto to a purchase.
Sanctions screening
United Nations sanctions listings on terrorism and proliferation take direct effect in Georgia from their publication by the UN committee. Every person, not only banks, must make no funds or assets available to a listed person and must notify the Financial Monitoring Service. Obliged entities must screen the client, the beneficial owner and counterparties against the UN list before onboarding and before transactions. For other sanctions regimes, the National Bank decided in September 2023 not to apply US, EU and UK sanctions related to Russia to Georgian citizens without a Georgian court conviction, while TBC Bank and Bank of Georgia said they would continue to apply all international sanctions.
Georgia's standing, and why your home bank cares
MONEYVAL adopted Georgia's fifth-round evaluation report on 17 September 2020, and Georgia has since been in enhanced follow-up; the follow-up report released in December 2024 again recorded the gap on real estate agents. Georgia is not on the European Union's list of high-risk third countries, last amended in January 2026, and it is not among the jurisdictions under increased monitoring by the FATF after the June 2026 plenary. For a buyer sending money from Europe, that means the transfer does not fall under the enhanced measures EU law reserves for listed countries, although the sending bank still applies its own checks to a large international payment.
Preparing a source-of-funds file
Trace the money
Write down, in a few lines, where the purchase money comes from: salary savings, a sale, a loan, an inheritance, a gift or a business.
Collect the matching documents
For each source, the document that proves it, such as a sale contract with the bank statement showing receipt, or a loan agreement.
Keep the trail unbroken
Move the money between accounts in your own name and avoid cash in between.
Prepare translations early
Ask your Georgian bank which documents need a translation and whether it needs certification.
Send before the transfer
Give the receiving bank the file before the money arrives, not after it is held.
Risks and exceptions
- Splitting payments. Linked transactions are added together under the law.
- Cash in the chain. It breaks the evidence of where the money came from.
- Third-party payments. Money sent from someone else's account raises a new source question.
- Crypto without statements. The origin of virtual assets is part of the enhanced checks.
- Waiting to be asked. A held payment cannot be explained to you while it is examined.
Frequently asked questions
Do real estate agents have to check my money?
No, Georgian law does not list agents as obliged entities; banks, notaries, lawyers and the registry are.
From what amount do the checks apply?
One-off transactions above GEL 15,000, wire transfers above GEL 3,000, and any amount if there is a suspicion.
Will the Public Registry report my purchase?
Under the FMS rules, sales above GEL 300,000 are reported automatically; a report is not an accusation.
Why will the bank not tell me why my payment is held?
The law forbids telling a client that a transaction is being examined or reported.
Can I pay for a flat in cash?
We found no legal cap, but cash above set thresholds is reported and leaves no trail of origin.
Can I buy with crypto?
Payments in virtual assets are prohibited unless a National Bank act allows them; convert through a registered provider first.
Is Georgia a high-risk country for EU banks?
No, it is not on the EU list of high-risk third countries as last amended in January 2026.
How long are my documents kept?
Five years after the relationship or transaction ends, extendable by up to five more.
Sources
- Law of Georgia on Facilitating the Prevention of Money Laundering and the Financing of Terrorism (Articles 3, 4, 10-13, 17-1, 18-21, 25-28, 36, 41), Legislative Herald of Georgia (accessed 18 October 2026)
- Financial Monitoring Service Order No 1 of 5 June 2020 on reporting, Legislative Herald of Georgia (accessed 18 October 2026)
- Financial Monitoring Service Order No 2 of 17 November 2025, Legislative Herald of Georgia (accessed 18 October 2026)
- Organic Law of Georgia on the National Bank of Georgia (Articles 34, 39-1, 52-5), Legislative Herald of Georgia (accessed 18 October 2026)
- Virtual asset service providers: questions and answers, National Bank of Georgia (accessed 18 October 2026)
- MONEYVAL approved the fifth-round mutual evaluation report of Georgia, National Bank of Georgia (accessed 18 October 2026)
- Report on MONEYVAL's December 2024 follow-up report on Georgia, Civil.ge (accessed 18 October 2026)
- EU list of high-risk third countries, European Commission (accessed 18 October 2026)
- FATF jurisdictions under increased monitoring, June 2026, New Zealand Department of Internal Affairs (accessed 18 October 2026)
- Report on the National Bank's September 2023 sanctions decision, Civil.ge (accessed 18 October 2026)
Change log
- - Explainer published from the AML Law (consolidated 1 April 2026), the Financial Monitoring Service reporting rules, the Organic Law on the National Bank and MONEYVAL, EU and FATF sources.