Travel Perks or Privacy: TBC Concept (Georgia) vs ABank (Kyrgyzstan)

Two of the accounts we open cost exactly the same: EUR 1,337. One is a premium TBC Concept 360 account in Tbilisi, Georgia. The other is a non-CRS account at ABank (formerly Aiyl Bank) in Bishkek, Kyrgyzstan. Because the price is identical, nobody ever picks one for being cheaper. They pick based on what they actually want the account to do.

The short version: Georgia buys you travel benefits, Kyrgyzstan buys you privacy. And if you hold a Paraguayan tax residency, Georgia can quietly buy you both, at least until Paraguay starts exchanging data in 2028.

One thing to be clear about before any of it: a non-CRS account changes who tells your tax office, not what you owe or what you have to file. What you are buying is distance from automatic, unexamined disclosure, not immunity from a properly made request.

Fees, card terms and CRS positions below were verified in September 2026. Where a number has moved since we last wrote about it, we say so in the text.

What is in here

• Which one is yours
• How CRS actually decides who hears about your account
• Privacy is not the same thing as hiding
• TBC Concept, in detail
• ABank (Kyrgyzstan), in detail
• What is actually insured
• Head to head
• Where each one disappoints
• Why some clients hold both
• When you should buy neither
• How we open them
• Questions we get

Which one is yours

How CRS actually decides who hears about your account

Most people get this wrong in the same way. Under the Common Reporting Standard, a bank does not report you to the country that issued your passport. It reports you to the country where you say you are tax resident, confirmed by a self-certification form you sign at account opening and cross-checked against what the bank knows about you: your address, your phone number, where your money comes from.

Then a second condition has to be met. Even with your tax residence on file, the bank’s country can only send the report if it has an active exchange relationship with that jurisdiction. No relationship, no transmission. The data simply has nowhere to go.

What Georgia sends

Georgia is in the CRS. It signed the multilateral agreement on 9 November 2022 and made its first automatic exchange in September 2024. It sent data to 34 partner jurisdictions for the 2024 exchange year and 44 for 2025. Every EU member state is on that list.

So if you are tax resident in Slovakia, Czechia, Germany or anywhere else in the EU, a Georgian account will be reported to your tax office once a year: balance, interest, account number, your name. That is not a flaw in the product, it is what the bank’s own terms say it does. It is also why a Georgian account is a stability play rather than a privacy one. Your money sits outside the EU, out of reach of an EU Account Preservation Order, in a modern banking system with a personal banker who answers the phone. It is not hidden.

What Kyrgyzstan sends

Nothing. Kyrgyzstan has not signed the CRS multilateral agreement and does not appear on the OECD’s list of jurisdictions that have committed to start exchanging. We checked the OECD signatory list again while writing this: 122 jurisdictions, Georgia at number 43, Panama at 92, no Kyrgyzstan anywhere on it.

It runs deeper than one list. CRS sits on top of an older treaty, the OECD and Council of Europe Convention on Mutual Administrative Assistance in Tax Matters, which is the legal ground the exchange agreement stands on. Around 150 jurisdictions are party to it. Kyrgyzstan is not one of them, so the machinery that would carry an automatic report is not merely unsigned, it is absent.

What is absent is the automatic feed, and it is worth being precise about that. Kyrgyzstan has around three dozen double-tax treaties, and those carry the standard clause letting a foreign tax authority ask about a named person. Being asked about is not the same as being reported every year without anyone asking, and the whole of this article turns on that difference.

This is the durable version of the privacy pitch. Other popular non-CRS jurisdictions are non-CRS because they have not got round to it yet, and several have already announced a start date. Kyrgyzstan has neither signed nor committed, which is a different and more stable position.

The Paraguayan route, and what changes in 2028

A TBC Concept account is opened on your passport, and the tax residency you declare does not have to match it. An Italian citizen with Paraguayan tax residency opens the account on the Italian passport and self-certifies as tax resident in Paraguay.

Georgia now has a reportable account whose owner is tax resident in Paraguay, and no exchange relationship with Paraguay. Paraguay is not a CRS-MCAA signatory and receives nothing. So the report is prepared and goes nowhere. You get the full Georgian travel package with the reporting consequence of a Kyrgyz account.

Three conditions have to hold:

• The residency has to be real. A self-certification is a signed statement, and the bank tests it against what it can see. You need the Paraguayan cédula, an address, ideally a RUC tax number. We can arrange the residency, but it is a separate process with its own timeline, not a form you tick.
• Your old residence must actually be gone. If you are still tax resident in the EU as well, you have two tax residences, one of which Georgia does exchange with. Dual residence defeats the whole arrangement.
• Paraguay has committed to 2028. This is the one that gets left out of most marketing, including some copying our own articles. Paraguay exchanges nothing today, but it told the OECD it will begin first exchanges by 2028, voluntarily. CRS exchanges normally cover the preceding calendar year, so account data from around 2027 could sit in that first batch.

Paraguay has not signed the CRS-MCAA yet and commitments have slipped before, so 2028 is a stated intention rather than a scheduled event. But if your reason for holding the account is that nobody reports it, you are relying on something with a publicly announced end date. Kyrgyzstan does not have one.

Privacy is not the same thing as hiding

Non-CRS means no automatic report. It does not cancel your obligations at home. If you are tax resident in an EU country, you still declare your income and, in most member states, the foreign account itself. A Kyrgyz account changes who tells your tax office. It does not change what you owe or what you must file. Anyone selling it as a way to stop declaring income is selling you a tax-evasion charge with a bank card attached.

With that said, there is a great deal of legitimate ground between “reported automatically to a dozen agencies” and “hidden from the state.” Consider what the automatic-disclosure machinery actually looks like now:

• Every EU state runs a central bank-account register (5AMLD, Directive 2018/843). The 2024 AML package extends these to securities and crypto and interconnects them across the EU through BARIS, expected around 2029. Financial intelligence units and the new AML Authority reach into them without a court order.
• In Slovakia, §91(4) of the Banking Act lets the intelligence service obtain your accounts, balances and transaction history on a written request. No consent, no judge.
• An EU Account Preservation Order (Regulation 655/2014) can freeze your account before you have been heard, but only if the account is located in an EU member state. Georgia and Kyrgyzstan are both outside its reach.
• Concentration risk is real. Capital controls, wartime transfer limits and frozen deposits are not exotic. Ukraine, Lebanon, Nigeria and Egypt have all done a version of it to ordinary residents within the last few years.

Wanting your banking outside that apparatus, while still filing an honest tax return, is a coherent position. It is the position these accounts are built around, and we listed the everyday restrictions they remove in Your Money, Their Rules. What neither account gives you is immunity: both banks answer court orders and mutual legal assistance requests, and banking secrecy in the old Swiss sense has not existed anywhere for years. The difference is between a yearly automatic feed and a request someone has to justify.

TBC Concept, in detail

This is the Georgian side in full: what the two tiers cost, what the cashback is actually worth, how money gets in and out, and the Travel Card that carries most of the argument.

The two tiers

TBC Concept comes in two levels, and non-residents pay slightly more than Georgians:

We open the 360 tier for clients, and set out the full case for it in seven reasons you want a TBC Concept account. The personal banker alone justifies the difference: when your passport expires, when a payment gets stuck in compliance, when you want the account’s base currency switched from lari to euro, you write to a named person instead of a queue.

Cashback that behaves like money

The 360 pays 0.7% on card payments, and up to 2.1% in one category you choose each month in the app: groceries, pharmacy or fuel, at TBC’s own terminals. The category boost is Georgia-only for the obvious reason that it is tied to TBC terminals, but the base rate also lands on spending abroad, which is unusual for a bank this cheap. It is paid as cash, not as points redeemable only in Tbilisi, so it is worth something to someone who never sets foot in Georgia.

Getting money in and out

Accounts are multi-currency: GEL, USD, EUR, GBP. Payments from the EU normally land in one to two days.

The trick worth knowing is topping up from a foreign card. International transfers to Georgia are expensive, so TBC lets you push money onto your own account from any foreign Visa or Mastercard, a Revolut card included. The published rate is up to 1%; it has been running at 0% for a long time. Check what the app quotes before you rely on it for a large amount.

Outgoing foreign-currency transfers through digital channels cost 0.2%, minimum 15 $/€, maximum 150 $/€. Older write-ups, including ours, described this as a flat $15 fee. That was the minimum, not the price.

The Travel Card

This is the part nobody else in this price range offers, and it is the single best reason to choose Georgia. The Miles&Smiles Visa Signature Travel Card is available to Concept 360 clients for 30 GEL a month, roughly 9.30 €, ordered through your personal banker. What it carries:

• Thirty lounge visits a year, with up to four guests each time, and no minimum-spend condition. Spend 5,000 GEL a month and it goes unlimited. Without the Travel Card, a plain Visa Signature gets 10 visits a year and only if you spent 1,500 GEL in the preceding 35 days.
• Up to 30 Fast Track uses a year, also for four guests, in Tbilisi and at selected airports in Europe and Turkey.
• Turkish Airlines miles. Five miles per lari on Turkish Airlines tickets bought with the card, so a 1,000 GEL ticket returns 5,000 miles. Everyday travel spending in GEL earns 30% of the transaction value in miles, credited daily.
• A 30 GB roaming package for Europe and Turkey, once a year.
• Insurance that actually covers you: a free 30-day TBC Insurance travel package each year with no co-payment, plus up to 180 days of Visa travel insurance annually when the trip is paid for with the card.
• Bolt at 50% off for airport rides in Tbilisi, Batumi, Kutaisi, Berlin, Munich, Paris, London, Prague, Zurich, Madrid, Barcelona, Budapest and Baku.
• The Visa Concierge chatbot, around the clock, for flights and hotels.

Individual campaigns rotate and expire; we tracked a season’s worth of them in this breakdown of the 2026 summer offers. The card itself, the lounges and the miles do not expire.

Crypto

Georgia has the better crypto infrastructure of the two, and we have written about how to move crypto in and out of TBC in detail. TBC works directly with Cryptal, Georgia’s largest exchange, and fiat withdrawals land almost instantly. Withdrawing to your TBC card rather than your account cuts the fee from 2% to roughly nothing.

Our order of preference, safest first: our private Signal P2P group for Georgian account holders; then Cryptal; then Binance P2P, which works but pairs you with strangers, and repeated trades are the fastest way to get a Georgian account frozen. If you use Cryptal, also run ordinary payments through the account. An account that does nothing but receive crypto looks like exactly one thing to a compliance officer.

ABank (Kyrgyzstan), in detail

One naming note first: the bank we call Aiyl Bank was legally renamed OJSC “ABank” on 12 March 2026. The SWIFT code (AIYLKG22), the tax number and every existing account and contract stayed the same, and both names still appear in the app and in SWIFT directories.

Fourteen currencies and no local ties required

You need no residency, no local income and no connection to Kyrgyzstan, which is the reason we started offering the account at all. Compare that with Paraguay, where a full account without limits requires residency and declared local income, or you are capped at about USD 1,000 a month.

The multi-currency account opens with one tap in the app and holds USD, EUR, GBP, CHF, AMD, AZN, GEL, KGS, KZT, KRW, TRY, RUB, AED and CNY.

One gotcha that breaks accounts: when you open the multi-currency account, the branch has to be set to Филиал “ВИП центр”, the VIP Centre branch. Pick a different branch and incoming and outgoing transactions on that account get declined. Our clients get told this; people who open alone often do not.

The Visa Infinite card

Kyrgyzstan hands a non-resident a Visa Infinite, Visa’s top consumer tier. TBC Concept 360 stops at Visa Signature, one step below, though it also carries a Mastercard World Elite, which is Mastercard’s own equivalent of Infinite. The tiers are closer than the names suggest, and what separates the two cards is not the metal but what each one actually pays out. The annual fee is 150 USD for a dollar card and 150 € for a euro one, and the card is valid five years; the first year is included in our package. The tariff sheet also offers 750 up front for five years, in whichever currency the card is issued in, which is simply five annual fees and not a deposit. A smaller 60 USD/EUR stays locked on the card account for the life of the card and is returned when it expires or you close it.

What it costs to use:

Daily limits sit at 5,000 USD/EUR each for ATM withdrawals, card purchases and online payments, with a single ATM withdrawal capped at 25,000 KGS at ABank machines. You can raise limits for up to 30 days from the app or through your manager.

Visa Infinite privileges, and the one that does not apply to you

The card carries airport lounge access through the Visa Airport Companion app (DragonPass), which the bank puts at six visits a year, fast track at airports in 17 European cities, free luggage wrapping at Bishkek Manas, a 24-hour concierge line, Visa’s Global Customer Assistance for emergency card replacement and cash, purchase protection on the Visa terms, telemedicine consultations, and partner discounts including Booking.com at 6%, Agoda at 12% and Avis at 35%.

There is one exception. Visa’s headline figure for Kyrgyzstan is international travel insurance covering up to USD 2.5 million. The bank’s own note says the travel and medical insurance of this programme covers citizens of the Kyrgyz Republic only. As a non-resident cardholder, assume you are not covered and keep your own travel policy. Anywhere you see that 2.5 million quoted for foreigners, including in older copies of our own material, it is wrong and we have corrected it. The other privileges are unaffected.

The VIP lounge at Bishkek Manas also comes with a condition that is easy to miss. Since 15 January 2026 it is free only if you spent at least 80,000 KGS (roughly 900 USD) on card purchases in the preceding 35 days, and the last five of those days do not count. Shop purchases and online payments count; cash withdrawals, card-to-card transfers and P2P or QR payments do not. The bank’s card page still advertises the lounge without the condition, so go by the announcement, not the brochure.

The insurance is the sharpest single difference between the two accounts. TBC’s travel insurance genuinely covers you. ABank’s does not.

Getting money in: the correspondent routes

Kyrgyzstan does not use IBAN, and ABank is reached through intermediary banks that differ by currency. Send euros on the dollar route and the payment does not bounce so much as wander off. The routes that matter:

The app shows the current route for whichever currency you have selected, and that screen is always fresher than any list. Two mistakes account for nearly every “my money vanished” message we get: spaces typed inside the account number or SWIFT code, and the wrong intermediary for the currency.

Getting money out: the window and the geography

Outgoing SWIFT transfers are made from the app, and the constraints are real:

• Euro transfers go only to the EU, Switzerland and the United Kingdom.
• Dollar transfers reach only certain countries and banks, and the current list comes from the call centre on 5511.
• Orders are accepted 09:00 to 16:30 Bishkek time, which is GMT+6, on business days. Send at 18:00 European time and you are queued for tomorrow.
• Anything connected to Russia, Belarus or the occupied Ukrainian territories may be stopped by the correspondent bank, with no guarantee the money comes back.

Nothing here is a dealbreaker. It is simply a slower, more deliberate account than a Georgian one, and worth knowing before you plan around same-day payments.

The SIM card you have to keep alive

This is the ongoing obligation people forget. Your account is tied to a Kyrgyz MegaCom number, and every login and transfer confirmation code goes to it. The plan costs 350 KGS a month, about 4 USD, and you keep a further 150 KGS sitting on the number as balance. That is roughly 48 USD, or 41 €, a year.

Let it lapse and you cannot log in. Incoming SMS in roaming is free, so the SIM can sit in a second phone or an eSIM slot anywhere in the world, but it has to stay topped up. TBC, by contrast, does not need a Georgian number at all; two-factor authentication runs inside the TBC app.

Crypto

Thinner than Georgia’s, but workable. Binance P2P is fast and reliable in Kyrgyzstan, considerably more so than in Georgia where the same behaviour attracts attention. Bybit P2P works there too. There is a local exchange, CoinX, though it only runs one way, from fiat to crypto. And there is our Signal P2P group, where clients clear fiat between each other’s Kyrgyz accounts.

What is actually insured

If the plan is to park a balance abroad, this is the number to look up before the cashback rate. Neither country protects deposits anywhere near the European level, and the two schemes differ in a way that matters more than the headline figures.

• Georgia: 50,000 GEL per depositor per bank, roughly 15,800 €, through the Deposit Insurance Agency. The cap rose from 30,000 GEL on 1 April 2026, the third increase since the scheme began in 2018. It covers residents and non-residents alike, in any currency, and pays out within 20 calendar days of a liquidation opening.
• Kyrgyzstan: 1,000,000 KGS per depositor, roughly 9,800 €, through the Deposit Protection Agency, raised from 200,000 KGS in 2023. One detail matters more than the amount: foreign-currency deposits are compensated in som, at the official rate on the day. Your euro balance is insured, but not in euros.

An account inside the EU is covered to 100,000 €, so both of these are a fraction of what you are used to. That is not an argument against either account, it is an argument about size. Below the cap a state scheme stands behind you. Above it you are lending to the bank, and the question becomes how sound the bank is: TBC is one of Georgia’s two systemic banks, and ABank is wholly owned by the Kyrgyz government, which cuts both ways, a state owner being a deep pocket and a political one at the same time.

The practical reading is that neither account is the place for money you cannot afford to have stuck in one country. Which is the same argument for spreading balances that brought you to a second jurisdiction in the first place.

Head to head

And what it costs to run

The 1,337 € is what we charge to open the account. The bank charges its own fees on top, and those are the ones you keep paying:

So a Georgian account settles at roughly 22 € a month once it is running, a Kyrgyz one at roughly 16 €, and the pair at about 38 €. Whether that is cheap depends entirely on whether you use the lounges.

Where each one disappoints

Georgia disappoints if you never fly. Strip out the lounges, the miles and the fast track and you are paying 13 € a month for a good multi-currency account with cashback, which is fine but no longer remarkable. And the cashback is drifting down, as the June 2026 cut from 0.6% to 0.5% on the lower tier shows.

Kyrgyzstan disappoints if you thought a Visa Infinite meant Visa Infinite everywhere. The card is the top tier and the benefits behind it are not. And for the life of the account you are quietly renting a mobile subscription, because the login codes have nowhere else to go.

Both disappoint if what you actually wanted was an account nobody can ever reach. Neither is that. Both banks respond to court orders and legal assistance requests. If your plan depends on nobody anywhere ever being able to ask, neither of these is the product you are looking for.

Why some clients hold both

The two accounts fail in different ways, which is the argument for holding both. The Georgian account is the one you spend from: the card works everywhere, the lounges are real, topping it up from a European card is free. The Kyrgyz account is the one that holds the balance, in a jurisdiction that reports to nobody and sits outside every EU freezing mechanism. Size that balance with the insurance section in mind, though: the account that reports to nobody is also the one with the thinner safety net, so anything well above 1,000,000 KGS is a judgement about ABank itself rather than about a state scheme.

Moving money between them is easy, because our clients already do it among themselves. Local transfers inside Georgia are instant, local transfers inside Kyrgyzstan are instant, and the Signal groups exist precisely so that a euro balance in one place can become a euro balance in another without a SWIFT fee.

Open both accounts and we pay you 5% back. The pair costs 2,674 €, and 5% of that is 133.70 €, which comes back to you as cashback once both accounts are open. Tell us in the Signal chat that you have taken both and send us a crypto wallet address; the 133.70 € goes out within 14 days of the second account opening.

When you should buy neither

We would rather talk you out of this now than argue about it later. Skip both accounts if:

• You only want a cheap card for holidays. Revolut or Wise do that for nothing. You are paying 1,337 € for an account outside the EU with a banker attached, and if that sentence does not describe a problem you have, it is not worth the money.
• Nothing regular flows through it. Dormant accounts are the ones that attract questions, and an account whose only activity is an occasional crypto payout attracts them fastest.
• You want Kyrgyzstan so you can stop declaring income. That is not a banking product, it is a plan to commit tax evasion with a slower card.
• You need money to move on the same day, in any currency, anywhere. Georgia is quick, Kyrgyzstan is not, and neither is your EU bank’s instant SEPA.

And if the Paraguayan route is what caught your eye, the residency is the part you need first. We handle that too: see how Paraguayan permanent residency works and whether it still makes sense in 2026 before you plan a Georgian account around it.

How we open them

Neither account requires you to fly anywhere. Both run on an apostilled power of attorney, and both land in about the same window: two to four weeks for Georgia, around three for Kyrgyzstan. The difference is who does the running.

Georgia. A five-minute form generates your power of attorney and passport declaration. Then comes the one step we cannot take off your hands: for Georgia we cannot arrange an international apostille, so you visit a notary and an apostille office yourself. Budget one to three weeks; we point you at the fastest local option in a private Signal chat that opens the moment you pay. Czech and Slovak clients are the exception and we do it for them, included in the price, though in Slovakia the passport apostille alone can take up to a month, so start early.

The apostilled documents go to our assistant in Tbilisi, and the Georgian translation, notarisation and bank visit take about a working week. A banker who handles international clients calls you for a short video verification. App access and card details arrive immediately, ready for Apple Pay or Google Pay; the physical cards ship anywhere in the world.

Kyrgyzstan works the other way round. There the international apostille does work for us, so wherever you live, our assistant handles the notary, the apostille, the courier to Bishkek and the certified Kyrgyz translation. Your part is ten minutes of documents online; the rest takes around three weeks. We then open the account on your behalf, collect the Visa Infinite card and the MegaCom SIM under your power of attorney, and DHL both to you anywhere in the world. The banker contacts you directly with your credentials.

Both include membership of our private Signal groups, including the P2P crypto trading groups where clients clear fiat between each other’s accounts without touching an exchange.

Closing an account works the same way as opening one. It runs on a power of attorney you sign with us, the same kind of document that opened the account in the first place, so the exit is a paperwork step rather than a button in the app, and it is when the deposit locked on the Kyrgyz card comes back to you.

Questions we get

The six that come up in almost every first conversation:

Is a Georgian bank account reported to my tax office?

Yes, if you are tax resident in a jurisdiction Georgia exchanges with. Georgia signed the CRS multilateral agreement on 9 November 2022 and made its first automatic exchange in September 2024, sending data to 34 partner jurisdictions for 2024 and 44 for 2025. Every EU member state is on that list. It is reported to the country where you are tax resident, not the country that issued your passport.

Is Kyrgyzstan in the CRS?

No. Kyrgyzstan has not signed the CRS multilateral agreement and has not committed to a start date. It is also not a party to the OECD and Council of Europe Convention on Mutual Administrative Assistance in Tax Matters, which is the legal ground CRS rests on, so no automatic report leaves the country. It does have around three dozen double-tax treaties, which allow a foreign tax authority to ask about a named person. Being asked about is not the same as being reported automatically.

What does a TBC Concept 360 account cost for a non-resident?

The bank charges 500 GEL a year, about 13 € a month, and the Miles&Smiles Visa Signature Travel Card is a further 30 GEL a month, about 9.30 €. Our service for opening the account remotely costs 1,337 €, the same as the Kyrgyz ABank account.

Does the ABank Visa Infinite travel insurance cover foreigners?

No. Visa’s headline figure of up to USD 2.5 million in travel and medical insurance covers citizens of the Kyrgyz Republic only, according to the bank’s own note. A non-resident cardholder should assume they are not covered and keep their own travel policy. The other Visa Infinite privileges are unaffected.

How much of the money is insured if the bank fails?

Georgia covers 50,000 GEL per depositor per bank, about 15,800 €, through the Deposit Insurance Agency, a cap raised from 30,000 GEL on 1 April 2026, and it covers residents and non-residents alike. Kyrgyzstan covers 1,000,000 KGS per depositor, about 9,800 €, and compensates foreign-currency deposits in som at the official rate. An EU account is covered to 100,000 €.

Do I have to travel to Georgia or Kyrgyzstan to open the account?

No. Both accounts are opened remotely on an apostilled power of attorney. For Georgia you arrange the notary and apostille yourself, one to three weeks, except in Czechia and Slovakia where we do it. For Kyrgyzstan we handle the notary, apostille, courier and translation wherever you live, and the whole process takes about three weeks.

Taking both? We pay 5% back: 133.70 € to a crypto address, within 14 days of the second account opening.

Still deciding? Write to us before you buy. If your answer depends on where you are tax resident, that is a five-minute conversation, and it changes which account we would recommend.

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Card fees and benefits verified against TBC’s published terms and ABank’s own tariff sheets and app in September 2026. CRS positions checked against the OECD’s signatory list and its status-of-commitments document. Bank terms change and campaigns expire; the app and your banker are always fresher than an article.