Clavestra Georgia

Clavestra Iveria Finance

The licensed operating entity of the Iveria federation.

Clavestra Iveria Finance LLC is a Tbilisi-incorporated Georgian limited liability company whose sole business is the operation, under National Bank of Georgia supervision, of the Iveria federation — a federated digital-asset custody and payment network backed one-to-one by attested reserves.

Status

Clavestra Iveria Finance LLC is in incorporation, with target registration in Q3 2026. The Federation Participant Agreement governing its relationship with sister entity Clavestra Labs LLC has been finalised and will be filed with the National Bank of Georgia as a companion document to the VASP application. The NBG VASP registration application is in preparation; target licence grant Q1 2027.

The company will hold no other licences in Georgia, will conduct no business outside the registered VASP scope, and will not carry on banking, securities, or insurance activities.

Corporate structure

Entity Detail
Legal form Limited Liability Company (Sps), Georgia
Registered office Tbilisi, Georgia (specific address pending incorporation)
Group parent Clavestra Capital Holdings Ltd (Malta, C113811)
Sister Georgian entity Clavestra Labs LLC (engineering and guardian operator)
Sister federation Clavestra Orbital GmbH (Lugano, Switzerland — VQF SRO)
Ultimate beneficial owner Mr Luuk Joseph Soons (sole founder and UBO of the Maltese parent)

 

All UBO documentation, source-of-wealth declarations, and fit-and-proper disclosures will be provided to the NBG as part of the application.

Licensed activity (subject to NBG registration grant)

Within the perimeter of the NBG Virtual Asset Service Provider framework, Clavestra Iveria Finance LLC will conduct the following service categories:

Custody of virtual assets. One-to-one reserve custody of Bitcoin, regulated stablecoins (USDT, EURC), and tokenised gold (XAUT) on behalf of operator-clients, held under threshold cryptography across the federation’s independent guardian set.

Exchange of virtual assets. Foreign-exchange conversion between Bitcoin, stablecoins, tokenised gold, and (subject to banking partnerships) major fiat currencies, on a documented OTC desk basis at institutional volume thresholds.

Transfer of virtual assets. Agent-to-agent and operator-to-operator value transfer over the Lightning Network, the federation’s internal rails, and (where supported) Liquid, Spark, and Taproot Assets settlement layers.

All product surfaces operate strictly within the licensed perimeter and under the same wallet-tier compliance architecture, Travel Rule obligations, and supervisory accountability.

The federation in one paragraph

The Iveria federation is a Fedimint-based federated digital-asset custody and payment network. Custody of Federation Reserves is held under threshold cryptography across a distributed guardian set of ten independent operators, with a 7-of-10 signing threshold. No single Guardian — including Clavestra Iveria Finance LLC itself — can move Federation Reserves unilaterally. Customer balances are represented within the federation as Chaumian-style privacy-preserving bearer instruments; identity, AML, and Travel Rule controls are conducted at the regulated counterparty layer by the licensed Operator. Reserves are cryptographically attested on a continuous published cadence, anchored to the Bitcoin base layer, and verifiable independently by the National Bank, by counterparties, and by the public.

The complete architectural and regulatory profile is set out in our NBG White Paper.

Compliance posture

  • Travel Rule. Travel Rule compliance is enforced at every peg-in and peg-out boundary above the prescribed threshold, orchestrated as a durable, auditable workflow with originator/beneficiary VASP resolution, sanctions screening, and human-in-the-loop escalation.
  • AML and sanctions screening. Integrated through Chainalysis, Elliptic, and TRM Labs with vendor-failover redundancy. Every screening result is recorded immutably with the transaction it relates to.
  • Wallet-tier architecture. Four progressive tiers (Tier 0 to Tier 3) under which identity-verification requirements escalate with transaction throughput. Tier 0 is capped at €900 per 24 hours — below FATF de-minimis thresholds and structurally analogous to physical cash. Tiers 1, 2, and 3 require progressive Know-Your-Business verification, guardian-threshold approval, and direct regulator sign-off respectively.
  • Proof-of-Reserves. Cryptographically attested on a published cadence, FROST-signed, OpenTimestamps-anchored, and transparency-log-published. The NBG receives the same cryptographic artefact as the public.
  • Reporting. Daily, monthly, quarterly, and annual reporting cycles to the NBG and FMS Georgia, with immutable workflow audit trails available on supervisory request without intermediated gatekeeping.

The full compliance framework is set out in Section 6 of our NBG White Paper.

Technical description

Clavestra Iveria operates a federated threshold-custody model. The cryptographic technique, FROST threshold signatures over a distributed-key-generation ceremony,  is the same family used by licensed MPC custodians: no single private key exists, and no party can move reserves alone. Iveria’s structure differs from single-operator MPC custody in its governance: the key shares are held by independent, named guardian operators under a Federation Participant Agreement, making the arrangement closer in legal shape to a multi-signature corporate trust, a consortium of named co-signers, than to a single custodian. Within that structure, Clavestra Iveria Finance LLC is the licensed mint operator: the sole entity holding the VASP registration, the customer relationships, the reserve accounts, and the supervisory relationship with the National Bank. The guardian operators contribute threshold signatures within Iveria’s licensed perimeter under the FPA; their signing role does not constitute independent virtual-asset-service activity and does not, on its own, place them within the VASP licensing category. Settlement (the licensed custody, exchange, and transfer activity) is conducted by Iveria; the protocol surfaces through which clients reach that settlement are distribution channels, not separate regulated activities.

Governance and personnel

Clavestra Iveria Finance LLC will be governed by a board comprising:

  • A Georgian-resident or work-permitted Director with day-to-day responsibility for licensed operations (in appointment)
  • The Group Chief Executive Officer, Vincent Soons
  • The Group Chief Strategy Officer, Luuk Soons
  • An independent non-executive director with relevant Georgian financial-services experience (to be appointed prior to licence grant)

A Money-Laundering Reporting Officer will be appointed prior to licence grant, with an independent reporting line to the board and to FMS Georgia. The compliance, AML/CFT, and supervisory-correspondence functions will be staffed in Georgia.

 

Banking and counterparty relationships

We are in early engagement with Georgian commercial banks to establish operating, compliance, and reserve-management relationships consistent with our licensed activity. Inquiries from regulated banking partners, institutional counterparties, and prospective operator-clients are welcomed.

 

→ Contact our institutional team

Clavestra Iveria Finance LLC · in incorporation, Tbilisi · Operating subsidiary of Clavestra Capital Holdings Ltd (Malta, C113811)