Source of Funds: What a Georgian Bank Asks For and How to Document It
Every foreign founder who banks in Georgia is asked where the money came from, usually more than once. The question has two forms, source of funds and source of wealth, and a legal basis that leaves the bank no choice. The documents that answer it for an employee, a freelancer, a founder, an investor and someone whose money came from crypto, how to lay out a trail a stranger can follow, and why the question comes back when a large transfer arrives.
Source of funds is one question: where did this particular money come from. A Georgian bank asks it because the anti-money-laundering law obliges it to understand the money that passes through an account, and the National Bank of Georgia, which supervises banks, has published a fine on a bank for failing to study where a client's funds came from. The answer is not a declaration. It is a short chain of documents: the event that produced the money, proof that you received it, and the path it took to the account. If a stranger can follow that chain in ten minutes, the question is answered.
2
Questions, not one
Source of funds is about this money; source of wealth is about everything you own
5 years
How long the bank must keep the file
After the relationship ends, under the Law at the time of writing
Ongoing
When the question applies
Before the account opens, during the relationship and when circumstances change
Source of funds and source of wealth are different questions
The Georgian Law speaks of the origin of a client's property, funds and convertible virtual assets. Banks use the international shorthand: source of funds for the money in a given transaction or account, source of wealth for how the person came to own what they own. A salary transfer has an obvious source of funds and tells the bank little about wealth. A founder who moves the proceeds of selling a company answers both at once.
| Aspect | Source of funds | Source of wealth |
|---|---|---|
| The question | Where did this money come from | How did you come to own what you own |
| Scope | One payment, one deposit, the opening balance | Your whole economic history |
| Typical evidence | Payslip, invoice, sale contract, statement showing the receipt | Career record, company ownership, a business sale, inheritance, tax returns |
| Usually asked | Of any client, in proportion to risk | Of higher-risk clients and politically exposed persons |
Why the bank is obliged to ask
A bank's duty does not end when the account opens. The Law requires it to monitor the relationship: to examine transactions and decide whether they fit what it knows about the client, the client's business or profession and the client's risk level, and where necessary the origin of the client's property and funds. For a client rated higher-risk it must go further: take reasonable measures to establish that origin, and obtain management's approval for the relationship. The same applies to a politically exposed person. If the bank cannot carry out its checks, it is not allowed to open or continue the relationship.
An accountable entity examines the transactions carried out within a business relationship to establish whether they correspond to the information it holds on the client, the client's commercial or professional activity and risk level and, where necessary, the origin of the client's property, funds and convertible virtual assets, and keeps that information up to date. For a client assigned a higher risk level it takes reasonable measures to establish that origin and obtains management approval to establish or continue the relationship.
The supervisor enforces this. The National Bank of Georgia publishes the monetary fines it imposes on the institutions it supervises. One notice, published in August 2026, records a fine on a commercial bank for failing, with respect to one client, to monitor the business relationship and to study the origin of transactions, activities, property and funds as the legislation and its internal procedures require. A compliance officer who asks you for one more document is keeping the bank out of a notice like that.
The Law prohibits a bank from telling a client that it is examining an unusual transaction or has reported one. So the officer may not be free to say why a question is being asked, and pressing for the reason achieves nothing. Answer what was asked, with the document, and ask what else would help.
The documents that answer it, by situation
| Where the money comes from | Core documents | What makes it convincing |
|---|---|---|
| Employment | Employment contract, payslips, statements showing the salary arriving | The employer can be found and the amounts match |
| Freelance or entrepreneur income | Client contracts, invoices, statements showing each payment | Invoices and receipts agree line by line |
| Dividends or the sale of a company | Registry extract, dividend resolution or sale agreement, statement showing the proceeds | The company's accounts support the profit or the price |
| Investments | Broker statements, sale confirmations, the statement that funded the purchase | Both the purchase and the sale are visible |
| Property sale, inheritance or gift | Sale contract and registry record, inheritance certificate, gift deed | Official documents plus the transfer itself; for a gift, the giver's own source |
| Crypto assets | Exchange statements in your name, the bank transfers that bought the assets, records of the sale | An unbroken line from bank money to assets and back |
Money that came from crypto
The Law names convertible virtual assets beside property and funds, so the origin of crypto is a legal question, not a matter of taste. In practice Georgian banks have a narrow appetite for it: many will not credit proceeds that arrive from an unidentified wallet or a peer-to-peer trade, and are more comfortable with a withdrawal from an exchange that verified you, supported by that exchange's own statements. The trail has to start in ordinary money: the bank transfers that bought the first assets, then the trading history, then the sale. A gap in the middle is read as the place where the story stops.
How to present a clean trail
- 1
Start with the event: the contract, the resolution, the payroll record or the sale that created the money, dated and signed.
- 2
Show the receipt: the statement page where the money arrives, complete, with your name and the account number visible.
- 3
Show the path: every account the money passed through between that receipt and the Georgian account, with no hop left out.
- 4
Add a half-page cover note that lists the documents and puts the amounts and dates in one small table.
- 5
Translate what the bank cannot read, and keep the originals to hand; never crop or edit a statement.
- 6
Send one ordered file with numbered pages, and tell the bank in advance when a large transfer is coming.
A flat sold at home and 150,000 dollars sent to Tbilisi
A founder sells an apartment in her home country for USD 180,000 and wants to move USD 150,000 to her personal account in Georgia, which normally receives about USD 4,000 a month. She tells the bank before she sends anything.
- 1Source of funds: the notarised sale contract with a translation, the property registry record showing the transfer to the buyer, and her home bank statement with USD 180,000 arriving from the buyer.
- 2The path: the same statement showing USD 150,000 leaving for her Georgian account, so the receipt and the transfer sit on neighbouring pages.
- 3The bank asks how she came to own the flat. That is source of wealth: she adds the 2015 purchase contract and the statements showing the loan repaid from her salary.
- 4The transfer arrives, is held for review because it is far above the account's usual pattern, and is released once the documents are matched to it.
USD 150,000 into an account that normally sees USD 4,000 was always going to be examined. The review lasted as long as it took to read five documents, because they had been prepared before the money moved and they agreed with each other.
Illustrative. The figures are invented, each bank sets its own review triggers and practice, and no timing can be promised.
The compliance interview
- It is usually a conversation with a relationship manager or a compliance officer, in a branch or by phone, built on the questionnaire you filled in.
- Expect to be asked what you do, who pays you, from which countries, how much a month, and what the account will be used for.
- Give the same answers as your documents, in the same figures. A turnover rounded up becomes a discrepancy with the first statement.
- If you do not know something, say so and send it afterwards. A guess that turns out wrong costs more than a day's delay.
- Mention planned large or unusual payments yourself: a property sale, a dividend, an investment coming in.
Why the questions return when a large transfer arrives
Checks are carried out before the relationship begins, at intervals while it lasts and when material circumstances change, and the Law tells a bank to examine any unusually large transaction, or unusual pattern of transactions, that has no apparent economic or lawful purpose. In practice a new account is opened on the turnover you declared, and a payment well outside that picture is usually not rejected but reviewed; the review asks the same question as at opening, this time about this money. Our article on bank and payment readiness shows the same mechanism for a company account.
Next step
The pack, assembled before the bank asks
We put together the source-of-funds pack for founders whose companies we register and take to a bank: the cover note and the ordered documents. We do not certify where money came from, and the decision on any account or transfer belongs to the bank.
See how the bank file is builtWhat this article does not answer
It gives no bank's internal thresholds, because each bank sets its own and they are not published. It does not cover what your home country requires when you sell an asset or move money abroad, or how it taxes the gain; ask an adviser there before the transfer, not after. And it offers no route for money that cannot be documented. We do not help present funds whose origin the client cannot show, and splitting a transfer into smaller amounts to stay under a review is itself a pattern a bank must examine. If your own company is an accountable entity, its duties are set out in our article on anti-money-laundering obligations.
General information, not legal advice. A bank's duty to establish the origin of funds is set by the Law of Georgia on Facilitating the Prevention of Money Laundering and the Financing of Terrorism and the rules of the National Bank of Georgia; each bank applies its own risk policy on top, and both the rules and the practice change.