Questions for your attorney

KYC/AML expectations Western investors test for

Questions for your attorney: KYC / AML for Georgian companies

Bring this page when you're 60–90 days from a fundraise. The work is calendar-driven — apostilles, translations, notarizations all take days you can't compress.

For my current cap table, who is the beneficial owner under the 25% FATF threshold, the 10% EU AMLD6 threshold, and US FinCEN BOI rules? Give me the list and confirm whether any are PEPs.

What is your standard NAPR document set for KYC-readiness — exactly which extracts, in which language, with which apostille / notarization treatment — and what does turnaround look like in calendar days?

For each beneficial owner, what is the minimum documentation we need on file before we approach Western investors? Do you have a checklist and a template self-certification?

Have you run our cap table against OFAC, EU, and UN sanctions lists? Against adverse-media databases? If so, what was the result and what's your retest cadence?

For every grant LocalCo has received (GITA, EU, EBRD, etc.) — do you have the award letter, disbursement records, and post-award reporting on file? If a fund asks for source-of-funds, can we produce it in 48 hours?

If we flip to Delaware, who handles FinCEN BOI filing within the 30-day window, and what are the consequences of a missed filing on the company and on me personally?

For our existing Georgian bank account: can you obtain a bank reference letter dated within the last 30 days, in English, with the standard fields a US fund will look for?

Which Georgian translator and notary do you usually pair with for fund-grade documents? Are they available on a tight timeline (say, 5 business days) and what's the cost?

If any current shareholder is unable or unwilling to provide a full KYC pack to a Western fund, what are our options — buy them out, restructure, document a workaround — and which is cheapest under our timeline?

What is the realistic week-by-week timeline from "we accept the term sheet" to "the wire clears," assuming KYC is the gating path? Show me where the slack is and where any single missing document blocks the entire chain.