Tbilisi, Georgia – January 15, 2026 – The Council of Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) has assessed that Georgia has achieved only limited progress in strengthening its framework against money laundering (ML) and terrorist financing (TF). This evaluation follows Georgia’s continued placement under enhanced follow-up procedures, emphasizing persistent gaps in implementation despite legislative advancements.
The latest MONEYVAL review underscores Georgia’s partial compliance with key Financial Action Task Force (FATF) recommendations, particularly in high-risk sectors like virtual assets, non-profits, and casinos. While technical compliance has improved in areas such as virtual asset service providers (VASPs), effectiveness remains hampered by inadequate risk understanding, resource constraints, and delays in targeted financial sanctions.
Background on MONEYVAL Evaluations
MONEYVAL, established under the Council of Europe, conducts periodic mutual evaluations of member states’ AML/CFT regimes against FATF’s 40 Recommendations. Georgia’s fifth-round report, adopted in 2020 and subject to ongoing follow-ups, rated the country compliant or largely compliant with 28 recommendations but identified deficiencies in 12 others.
Subsequent updates, including a 2024 assessment, praised specific measures by the National Bank of Georgia (NBG) in VASPs, upgrading compliance with FATF Recommendation 15 from “Partially Compliant” to “Largely Compliant.” Georgia now ranks among only seven of 27 MONEYVAL members at this level for virtual assets. However, the overall framework requires broader enhancements to exit enhanced monitoring.
Georgia’s National Risk Assessment (NRA), updated in recent years, identifies cash-heavy sectors, real estate, and trade-based laundering as primary ML vulnerabilities, alongside TF risks from regional conflicts. Despite a robust legal basis criminalizing ML and TF as autonomous offenses, practical application lags, with low conviction rates and underutilized financial intelligence.
Key Findings on Limited Progress
MONEYVAL’s assessment highlights several areas of stagnation:
- Financial Intelligence Utilization: Georgia’s Financial Monitoring Service (FMS) produces suspicious transaction reports (STRs), but law enforcement agencies (LEAs) underuse them for investigations. Only a fraction leads to prosecutions, signaling weak operational effectiveness.
- Non-Financial Sectors: High-risk sectors like casinos, real estate, and non-profit organizations (NPOs) face inadequate supervision. MONEYVAL flags NPO risks for TF abuse, urging risk-based oversight and transparency in funding sources.
- Targeted Financial Sanctions (TFS): Implementation of UN Security Council Resolutions (UNSCRs) on TF and proliferation financing has improved but falls short of “without delay” standards. Delays persist beyond hours, undermining swift asset freezes.
- Supervisory Resources: Regulators like the NBG and Service Agency for Accounting, Reporting, and Audit Supervision (SARAS) lack sufficient staff and training for risk-focused inspections, particularly in VASPs and DNFBPs (designated non-financial businesses and professions).
Positive strides include legislative reforms since 2023, such as enhanced customer due diligence (CDD) for VASPs and international cooperation mechanisms. Georgia convicted individuals for TF during the evaluation period but listed no terrorists or groups domestically.
Government Response and Reforms
Georgian authorities, led by the NBG and FMS, welcomed MONEYVAL’s feedback and outlined remedial actions. The NBG’s Anti-Money Laundering Inspection Department introduced VASP supervision protocols, including off-site monitoring and sanctions enforcement.
The 2025 NRA update prioritizes higher-risk sectors, with plans for digital STR platforms and LEA-FIU training. International cooperation expanded via bilateral agreements and regional forums, leveraging Georgia’s position between Europe and Asia to combat sanctions evasion.
Despite progress, Georgia remains in MONEYVAL’s enhanced follow-up, requiring biennial reports until at least 11 of 40 recommendations reach Largely Compliant or higher. Full compliance with six and partial in 11 underscores the “limited progress” narrative.
Implications for Georgia’s Financial Sector
This evaluation arrives amid Georgia’s EU accession aspirations, where robust AML/CFT frameworks are prerequisites. Weaknesses expose the economy to illicit flows, potentially deterring foreign investment in fintech and real estate. Virtual asset growth, while innovative, amplifies ML risks without stringent controls.
Stakeholders urge prioritizing NPO audits, TFS automation, and FIU-LEA integration. The IMF’s prior reviews echo these, noting resource gaps since 2013 improvements.
Georgia’s proactive stance—evident in 2024 VASP upgrades—signals commitment, but sustained implementation is critical to align with FATF standards and regional peers.
Global Context and Recommendations
MONEYVAL’s findings align with FATF’s gray-list scrutiny, though Georgia avoided listing. Comparatively, neighbors like Armenia advanced post-similar critiques. MONEYVAL recommends:
- Boosting STR dissemination and investigations.
- Risk-based NPO and casino supervision.
- TFS “go/no-go” decisions within hours.
- Capacity-building for supervisors.
As of January 2026, Georgia’s AML/CFT regime shows resilience but demands accelerated reforms to mitigate evolving threats like cryptocurrency laundering and geopolitical TF risks.