AML / KYC Policy

Colchis Digital LLC · Last updated: January 2025 · Effective: Upon NBG registration

1. Introduction & Legal Basis

Colchis Digital LLC ("Colchis Digital", "we", "us") is registered in Georgia as a Virtual Asset Service Provider (VASP) under the National Bank of Georgia (NBG) pursuant to NBG Order No. 94/04. This policy is established in accordance with: (a) Georgian Law on Facilitation of Prevention of Money Laundering and Terrorism Financing; (b) NBG VASP Regulation; (c) FATF Recommendations.

2. Know Your Customer (KYC)

All customers must complete identity verification before using our services. We collect:

  • Full legal name, date of birth, nationality
  • Government-issued photo ID (national ID card or passport)
  • Proof of address (utility bill or bank statement, dated within 3 months)
  • Live selfie for liveness verification
  • Source of funds declaration
  • PEP (Politically Exposed Person) and sanctions screening

3. Anti-Money Laundering (AML) Controls

We deploy an automated transaction monitoring system that detects suspicious or unusual transactions based on distributed ledger technology (DLT) data. Suspicious Activity Reports (SARs) are filed with Georgia's Financial Monitoring Service (FMS) as required.

We do not provide services to persons or entities subject to UN, EU, US (OFAC), or Georgian sanctions.

4. FATF Compliance & Counterparty Policy

Colchis Digital will not establish or maintain business relationships with any VASP or financial institution that: (a) is not licensed or registered in its home jurisdiction; (b) does not comply with FATF Recommendations; (c) is located in a FATF-blacklisted or greylisted jurisdiction with inadequate AML/CTF controls.

5. Prohibited Assets

We do not support privacy-enhanced coins or anonymity technologies that prevent transaction traceability on distributed ledger networks, as prohibited by NBG VASP Regulation Art. 8(2). This includes but is not limited to: Monero (XMR), Zcash (ZEC), Dash (DASH), and Grin (GRIN).

6. Record Retention

All customer identity records, transaction records, and due diligence documentation are retained for a minimum of 5 (five) years from the date of the transaction or the end of the business relationship, whichever is later, as required by Georgian law.

7. Contact

For AML/compliance queries: compliance@colchisdigital.ge