Sanctions, Crypto and Georgia: How One Foreign Listing Can Affect a Georgian Business

Sanctions are no longer only a bank issue

The EU’s 23 July 2026 package created, for the first time, a possible full third-country ban on crypto-asset services used to evade sanctions. It also expanded transaction bans and asset freezes and referred to crypto-related services based in Georgia and other jurisdictions. This does not mean every Georgian crypto business is sanctioned. It does mean banks, exchanges and foreign counterparties may pause transactions or request evidence.

If it happens in Georgia

Georgia’s Law on Facilitating the Prevention of Money Laundering and the Financing of Terrorism requires accountable persons to identify clients, assess risk, monitor suspicious activity and keep records. A name match is not automatically a final legal conclusion: identity, beneficial ownership, transaction, goods and counterparty must be checked. Dual-use goods may also trigger Georgia’s control legislation.

Business checklist

• Maintain a written sanctions-screening policy and update it.
• Screen the customer, beneficial owner, manager, supplier, bank and relevant crypto-asset risk.
• Record the source, time, result and decision rationale.
• Put sanctions, suspension, information-request and termination clauses in contracts.
• Preserve documents and do not make a spontaneous transfer after an account restriction.

Sanctions and AML controls overlap but are not identical. A bank refusal is not automatically unlawful, and ignoring document requests is not a safe strategy. Obtain a prompt, evidence-based legal assessment.

## წყაროები / Sources - Council of the EU, 21st sanctions package, 23 July 2026: https://skribi.consilium.europa.eu/en/press/press-releases/2026/07/23/21st-package-of-sanctions-eu-hits-russian-energy-financial-services-and-crypto-hard/ - FATF, February 2026 plenary outcomes: https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html - Law of Georgia on Facilitating the Prevention of Money Laundering and the Financing of Terrorism: https://matsne.gov.ge/en/document/view/4690334 - Law of Georgia on the Control of Military and Dual-Use Goods: https://www.matsne.gov.ge/en/document/view/2113659