National Bank rules: what changed
A standing monthly reading of regulatory movement at the National Bank of Georgia, written for the people inside licensed institutions who have to act on it, not for a newsletter.
1. What this note covers
Amendments to the supervisory framework, published guidance, consultation drafts and enforcement patterns visible in public decisions. Where a change affects an application already in the queue, we say so directly rather than describing the instrument.
2. Supervisory expectations are rising faster than the text
The clearest movement of the past year has not been in the rules but in what the supervisor expects to see evidenced. Governance documents that were accepted as statements of intent are now read as descriptions of an operating reality, and tested against it.
If your policies have not been revised since the licence was granted, they are already out of step with what a supervisory visit will ask for.
3. Where applications are stalling
Three items account for most delay: the fit-and-proper file for proposed directors, the AML officer appointment, and inconsistency between the operating model described in the application and the one the technical documentation implies. None of the three is resolved quickly once raised.
4. What to do this month
Read the risk matrix against the last quarter of actual transaction data. Confirm the reporting calendar against the current instrument rather than the one in force at licensing. Where a consultation draft is open, respond. The drafting still moves at that stage, and it does not move afterwards.
Licensed, or waiting on a decision? The research centre briefs clients monthly. Book a call with the licensing team.
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