Licensing of Crypto-Asset Operations in Uzbekistan

Digital transformation and the rapid development of blockchain technologies have compelled states to establish regulatory frameworks for activities related to crypto-assets. The Republic of Uzbekistan has become one of the first countries in the region to create a legal basis for licensing service providers in the field of crypto-assets. This article analyzes the content of the Regulation on the Procedure for Licensing the Activities of Crypto-Asset Service Providers, approved by the National Agency for Perspective Projects (NAPP).

According to the Regulation, crypto-assets are defined as property rights in the form of digital records in a distributed ledger, possessing value and an owner.

Key Entities:

• Crypto-exchanges (trading platforms for the purchase, sale, and exchange of crypto-assets);
• Mining pools (platforms for consolidating computing power);
• Crypto-depositories (issuance, primary placement, and storage of assets);
• Crypto-shops (services for buying and selling crypto-assets).

Licenses are granted exclusively to legal entities — residents of Uzbekistan — and are perpetual.

Licensing Requirements

The main conditions for obtaining a license include:

• Hosting servers within the territory of Uzbekistan;
• Storing operational and identification data for at least 5 years;
• Compliance with AML/CFT and personal data protection legislation;
• Prohibition of hidden mining and operations with anonymous crypto-assets;
• Prohibition of offshore companies’ participation in the authorized capital.

For crypto-exchanges, an additional requirement is a minimum authorized capital equivalent to 5000 base calculation units (BCUs), of which 3000 must be reserved in a bank.

Licensing Procedure

The applicant submits to NAPP a package of documents, including an application, information about founders and executives, and proof of payment of the authorized fund. A decision is made within 20 working days, of which 15 days are allocated for examination. The license is issued in electronic form with a QR code and published in the register.

Suspension and Revocation of Licenses

A license may be suspended in case of violations. Gross violations include: hidden mining, operations with anonymous assets, participation of offshore companies, reduction of capital below the required level, and placement of servers outside the country.

Revocation is possible by decision of NAPP or a court in cases of systematic violations, use of forged documents, or liquidation of the legal entity.

Control and Supervision

NAPP maintains an open license register, publishing information on license holders, their capital, issued licenses, and applied measures (renewal, suspension, revocation). NAPP’s decisions may be appealed in court.

Uzbekistan has established one of the most detailed and strict licensing systems for crypto-activities in the region. The system is aimed at:

• Ensuring market transparency,
• Reducing money laundering risks,
• Protecting consumer interests.

Future regulatory development involves adapting norms to new technological challenges and harmonizing with international standards in the field of virtual assets.

Licensing of Crypto-Asset Service Providers in Uzbekistan

Type of Service Provider	Key Licensing Requirements	Control Measures and Sanctions
Crypto-exchange	• Minimum authorized capital — 5000 BCUs (3000 reserved in a bank) • Servers hosted in Uzbekistan • Storage of operational and client data for 5 years • AML/CFT compliance, ban on anonymous assets	• Suspension or revocation of license if capital falls below required level • Prohibition of hidden mining and offshore participation • Judicial appeal of NAPP decisions
Mining pool	• Platform for consolidating computing power must be located in Uzbekistan • AML/CFT compliance and data storage requirements	• Suspension of license for non-compliance
Crypto-depository	• Services of issuance, primary placement, and storage of assets • Mandatory storage of information and correspondence for 5 years • Personal data protection	• Revocation of license for violations • Court measures in case of forged documents
Crypto-shop	• Services of buying/selling assets • Servers hosted in Uzbekistan • Ban on offshore company participation in capital	• Revocation of license for illegal operations • Inclusion in NAPP’s open register