Identify the transfer status, connect the payer and source of funds, and choose a complaint route that fits the actual issue. AML review, payment execution disputes and legal attachments require different assessments.
Legal support for this matter: Opening a Business Bank Account
Start with the actual transfer status
A transfer to Georgia that has left the sender's account but has not become available to the recipient needs a status investigation before a legal remedy is selected. Ask which institution currently holds or processes the money and whether the payment is awaiting documents, rejected, returned, being traced, or subject to an identified legal restriction. A debit notification establishes one event in the chain; it does not explain every later event. Keep the bank's exact terminology rather than replacing every delay with the word frozen.
This guide is for foreign individuals and businesses, including Chinese clients paying Georgian counterparties. It addresses document preparation and route selection, not a bank's willingness to accept a particular customer or correspondent route. Gather the transfer reference, amount, currency, dates, payer and beneficiary names, and the latest written message. If a contract payment is due soon, preserve that deadline separately and notify the counterparty accurately. A bank investigation and a dispute about whether the buyer paid are different questions.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing · Law on Payment Systems and Payment Services
A decision tree for the next step
Use four branches. If the bank asks for identity, ownership, purpose or funds-origin documents, organise a compliance response and ask how to submit it securely. If the instruction was rejected or returned, obtain the rejection reason and return reference, then reconcile the sender's statement. If the transfer was accepted but execution, amount or charges are disputed, investigate the payment-service complaint route. If an order or attachment is identified, obtain its available identifying details and have the restriction's legal basis and review procedure assessed.
Do not keep sending the same payment merely because the first one is slow. A second transfer may create duplicate settlement or another unresolved transaction. Before changing the beneficiary, payer or reference, clarify what problem the change would solve and whether the underlying agreement allows it. Ask the sending bank and receiving bank complementary questions: where did the sender's instruction go, and what has the recipient's bank actually received? Record a dated answer for each branch instead of relying on a telephone assurance that the money should arrive soon.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing · Law on Payment Systems and Payment Services
What a funds-origin explanation must connect
Georgia's AML law requires customer and beneficial-owner identification, an understanding of the relationship's purpose and monitoring of transactions. Article 10 also addresses consistency with the customer's activity and, when necessary, origin of funds. Those duties explain why a bank may need more than an invoice. Treat a request as a question about the whole chain: who earned or obtained the money, how it reached this payer, and why it is moving to this beneficiary now.
For salary savings, connect employment or income records to the account from which the transfer was made. For an asset sale, connect ownership, the sale agreement and the actual receipt. For company revenue, connect the customer contract, invoice and incoming settlement. For a shareholder contribution or loan, explain the contributor, authorisation and legal relationship. These are examples of helpful supporting records, not an exhaustive statutory checklist. Ask the bank which gap remains after submission; uploading a large folder without a clear explanation may leave the original question unanswered.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing
Different names and third-party payers
Compare legal names across the contract, invoice, bank account and payment instruction before explaining the transfer. A trading name, translated company name, Chinese name in characters, passport romanisation and abbreviated bank entry may all refer to the same person, but the connection should be documented. Prepare a small name-mapping sheet and attach the authoritative identity or company record. Do not silently replace the name appearing in an original document with a preferred English spelling.
A third-party payer creates another question: why is this person paying the customer's debt or funding the customer's purchase? Record the actual relationship, such as a disclosed parent company, lender or family member, and the authority or agreement behind the payment. Distinguish the person paying from the contractual buyer and the ultimate beneficiary of the transaction. A changed account communicated only in a chat should be independently verified through a known channel. This is a practical fraud and consistency control; it does not establish that the bank must accept a third-party payment.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing
Build a transaction file that can be followed
Create a chronology beginning with the payment instruction and ending with the last confirmed status. Include submission time and time zone, debit date, promised or estimated execution date, every document request, your response, and each return or trace update. Mark an estimate as an estimate. Keep the reference supplied by each bank, because different institutions may use different identifiers for the same transaction. Where a bank can provide a transfer message or tracking reference, preserve it with its explanatory cover rather than assuming it proves final credit.
The core checklist is: account statement showing the debit; payment instruction; contract and invoice; identity and company documents where relevant; evidence of the payer's relationship to the transaction; funds-origin records; bank correspondence; and any available restriction notice. Label the actual gaps. If the receiving bank says no funds were received, place that statement beside the sending bank's confirmation. This paired record is more useful than combining both statements into a vague assertion that the banks lost the money.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing · Law on Payment Systems and Payment Services
Respond accurately and through a verified channel
Put a short explanation at the front of the file: the purpose of the payment, who the parties are, the source of the money and which attachment supports each statement. Answer the bank's specific request first. If a requested document does not exist, explain why and ask whether an alternative record will address the same point. Separate an unavailable document from a document that exists but has not yet been obtained. Never create a replacement invoice or backdated agreement to make the history appear simpler.
Confirm that the request comes from the bank through a known contact or authenticated channel. Share only the relevant records, preserve a complete original set, and record what was disclosed. A translation should identify the source document and explain name or date conventions rather than conceal discrepancies. For Chinese-language records, a consistent bilingual index can help the bank see which attachment answers which question. Whether a translation needs a particular certification or format should be checked with the receiving institution instead of assumed for every document.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing
Make the bank complaint concrete
A useful complaint identifies the transaction and the conduct being challenged. State the last confirmed facts, the information you requested, the answer received and the practical remedy sought. That remedy may be a documented status explanation, investigation of an execution error, correction of charges, or clarification of missing documents. Attach a compact chronology and key records. Ask for acknowledgement and a complaint reference; keep the submission date and channel. Explain urgent contractual consequences without describing an unverified event as bank misconduct.
The NBG's general consumer FAQ says the institution should respond to a complaint within one month. That is a complaint response rule, not a promise to release the transfer within a month. A payment-service complaint has a more specific statutory framework, so do not calculate its procedure using the general FAQ alone. If a response arrives without resolving the status, compare it with the issues actually raised and identify what remains unanswered. Repeatedly demanding immediate unfreezing can be less informative than asking a precise question that the bank is legally able to answer.
Official sources: NBG consumer protection FAQ · Law on Payment Systems and Payment Services
When the payment dispute route may fit
For payment-service complaints, Article 41¹ provides a decision within 15 working days from receipt of the complaint, with a reasoned extension for causes outside the provider's control and a total ceiling of 35 working days from receipt. Filing on a non-working day counts as received on the next working day. Under Article 41², the provider complaint must remain unsatisfied within the prescribed period, including no answer, or be only partly satisfied before the commission route is available. Qualifying user status and dispute value also matter: the ceiling is GEL 100,000 or equivalent. The commission filing period is no later than six months from the complaint to the provider. Companies must also meet the applicable NBG eligibility criteria.
An execution delay, incorrect transaction or disputed commission may fit this route; a dispute solely about why a compliance restriction exists needs separate assessment. The current law also provides exclusions where the same dispute is already before a court or arbitration. Preserve the bank complaint and response before deciding which forum to use. Do not assume an overseas intermediary is directly subject to the Georgian commission. Identify the Georgian provider's alleged duty and the part of the transaction within the relevant regime; another country's provider and rules may also matter.
Official sources: Law on Payment Systems and Payment Services · NBG Dispute Resolution Commission
Regulatory review and legal restraints
The NBG accepts consumer complaints through its official channel, but filing a complaint does not itself settle entitlement to funds or cancel an order. Separate a request for consumer-protection review from a request to lift a court attachment or another authority's restriction. Obtain the issuing body, date, case or document reference, scope and available notice if a formal restraint is identified. A lawyer can then determine the competent review route and what information is needed from the account holder.
AML Article 28 limits disclosure of specified investigations and reports, so a bank may be unable to give every detail you ask for. Article 36 concerns a particular Financial Monitoring Service suspension instruction, with its own conditions and counting rules; it is not a universal maximum for every bank hold. Do not convert that provision into a general three-day release promise. Likewise, the commission's review period describes dispute handling, not how long the recipient must wait for unrestricted access. The precise restriction matters more than a generic countdown copied from an unrelated procedure.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing · NBG consumer claim form · Law on Payment Systems and Payment Services
A hypothetical Chinese buyer and a Georgian supplier
Imagine a Chinese trading company paying a Georgian supplier for equipment. The contract names the buyer, but the payment comes from a related company and uses an abbreviated beneficiary name. The sending bank confirms a debit, while the recipient is asked to explain the payment. This is a hypothetical illustration, not a reported client matter. The first task is to confirm the transfer's present status; the second is to connect the companies and payment purpose through genuine records.
The recipient could organise the signed contract, invoice, account details originally confirmed by the supplier, relationship explanation, authorised payment instruction and sender statement. A name-mapping page explains abbreviations. A separate chronology records what each bank confirmed and when. If the bank later confirms return, reconcile that return instead of continuing to request release of money no longer held there. If an execution error is alleged, formulate that complaint specifically. Meanwhile, the buyer and seller should address delivery and payment deadlines in writing; neither should infer a contract amendment from a bank status update.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing · Law on Payment Systems and Payment Services
Prepare the handover and recheck the rules
Before a legal consultation, write a one-page problem statement with the current status, unanswered question, amount, parties, deadlines and requested outcome. Identify the person entitled to communicate with each bank and any representation documents required. Bring originals or reliable electronic records rather than only a collection of cropped screenshots. Explain whether a complaint has already been filed, whether money has been returned and whether any court or arbitration is pending. These facts can change the available route.
Sources were checked on 3 October 2026, using current Georgian legislation where the English page showed an earlier edition. This guide does not supply a bank-specific release timetable, claim that a particular nationality determines the result, or guarantee a regulator will unblock a transfer. Recheck the operative law, provider terms and relevant NBG rules before filing, especially eligibility for a company or a transaction involving overseas providers. The most useful immediate outcome is an accurate file that lets the next decision address the actual obstacle instead of an assumed one.
Official sources: Law on Facilitating the Prevention of Money Laundering and Terrorism Financing · Law on Payment Systems and Payment Services · NBG consumer protection FAQ
Important noteThis material is general information, not personalised legal advice. Recheck current law, official practice, fees and deadlines against your facts before acting.