Blockchain, Cryptocurrency and Fintech

Uzbekistan regulates crypto-asset activity through a licensing regime administered by the National Agency for Perspective Projects. Providers of exchange, custody, mining and issuance services require a licence, and activity conducted without one is unlawful — which makes the regulatory position the first question for any project in this sector, not a later one.

Digests Global Law Firm advises technology companies, financial institutions and investors on the legal framework applicable to crypto-assets, distributed ledger technology and financial technology in Uzbekistan.

Our practice in this area covers:

• Licensing of crypto-exchanges, crypto-depositories, crypto-shops and mining pools
• Requirements applicable to the issue and circulation of crypto-assets
• Structuring of projects involving the issue of tokens, and analysis of whether an instrument falls to be treated as a security
• Anti-money-laundering obligations of crypto-asset service providers, including identification and monitoring requirements
• Licensing and regulation of payment services and electronic money
• Requirements of the Central Bank applicable to financial technology and to cooperation between banks and technology providers
• Currency control and the cross-border movement of funds
• Taxation of transactions in crypto-assets
• Personal data, information security, and the requirements on data localisation
• Smart contracts, and their treatment under the civil legislation
• Regulatory engagement, including participation in the regulatory sandbox regime

The regulation of this sector is developing, and the treatment of a new instrument is not always settled. We identify where the position is established and where it is not, rather than presenting the latter as though it were the former.