Uzbekistan’s National Agency for Perspective Projects (NAPP) has drafted regulations that would introduce substantial fines for foreign companies providing crypto-asset services to Uzbek residents without a licence or in breach of national requirements.
The proposed framework would also cover violations involving anti-money laundering and counter-terrorist financing obligations, personal-data rules and crypto-asset advertising. The measures have not yet been presented as final law, meaning the penalties and procedures could still change before adoption.
Proposed fines for violations
Under the draft, the largest penalty would apply to foreign legal entities conducting crypto-asset activities in Uzbekistan without the required licence. Such activity could result in a fine of up to 25,000 base calculation values (BCVs).
Uzbekistan’s current BCV is 412,000 soums. If that amount remains applicable when the rules are enforced, the maximum proposed penalty would be approximately 10.3 billion soums. The final financial impact, however, would depend on the BCV in force when a fine is imposed.taxsummaries.
The draft sets out separate penalties for other categories of non-compliance:
| Violation | Proposed maximum fine |
|---|---|
| Providing crypto-asset services without a required licence | 25,000 BCVs |
| Breaching personal-data storage and processing requirements | 15,000 BCVs |
| Violating anti-money laundering, counter-terrorist financing or proliferation-financing rules | 15,000 BCVs |
| Breaching crypto-asset advertising requirements | 10,000 BCVs |
At the current BCV, the proposed 15,000-BCV fine would equal about 6.18 billion soums, while the 10,000-BCV penalty would amount to approximately 4.12 billion soums. These calculations are indicative rather than fixed monetary penalties because the BCV may change.
The proposal states that payment of a fine would not remove any other liability under Uzbekistan’s crypto-asset legislation. A foreign company could therefore remain subject to additional administrative, civil or criminal consequences where applicable.
How NAPP would impose penalties
The draft would give the NAPP director or a deputy director authority to issue a decision imposing a fine. Such decisions would be based on recommendations from a special working commission made up of an odd number of NAPP employees.
The commission would assess the circumstances of each case rather than applying an automatic penalty solely because a violation had occurred. Its review would take into account the frequency and duration of the conduct, the effect on crypto-asset market participants and any corrective steps taken by the foreign company.
This approach would allow the regulator to consider whether a company had attempted to remedy a breach, restrict unlawful activity or cooperate with the authorities. It would also give NAPP discretion to distinguish between isolated and continuing violations.
The draft would establish time limits for enforcement. A fine could be imposed no later than six months after the violation was discovered and no later than three years after the violation was committed.
After making a decision, NAPP would be required to send the foreign company an official notice within three working days. The notice would identify the amount of the fine and provide payment details.
The company would have 15 days from receiving the notice to pay. If it failed to do so, NAPP would seek compulsory recovery through the courts.
Appeals and public disclosure
The proposal would provide foreign crypto companies with two routes to challenge a penalty. A company could submit an appeal to NAPP’s Appeals Council within 15 days of receiving the notice or challenge the decision directly in court.
The Appeals Council would be expected to review a complaint within 15 days. The payment deadline would be suspended while the appeal was under consideration, preventing enforcement of the disputed fine before the internal review had concluded.
NAPP would also be permitted to publish information about identified violations and the penalties imposed on foreign companies. Public disclosure could expose non-compliant firms to reputational damage in addition to the financial consequences of a fine.
The publication provision may be particularly significant for overseas exchanges and other digital-asset businesses that serve Uzbek customers remotely. Even where a company has no locally incorporated entity, disclosure by the national regulator could alert customers, financial institutions and other authorities to the alleged conduct.
Existing licensing framework
The proposal would strengthen an already structured licensing regime for crypto-asset service providers in Uzbekistan. NAPP’s official framework lists crypto-exchanges, mining pools, crypto-depositories and crypto-stores among the activities requiring authorisation.
The agency states that licensed activities may be carried out only by legal entities resident in Uzbekistan. Licences are issued separately for each category of activity and are valid for an unlimited period. NAPP’s licensing page says applications are normally decided within 20 working days.
Licensed providers must operate electronic platforms or related technical systems on servers located in Uzbekistan. They must also retain information on crypto-asset transactions, customer identification data and communications with platform participants for five years.
In addition, providers are required to comply with legislation covering crypto-asset activity, money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction. They must also follow personal-data and advertising requirements and provide information requested by the licensing authority.
The framework prohibits hidden mining and operations involving anonymous crypto-assets, including the mining of anonymous crypto-assets. NAPP also restricts management participation by individuals linked to terrorism, proliferation financing, organised crime, corruption, drug trafficking or specified economic and financial crimes.
Crypto-exchanges face additional capital requirements. According to NAPP, an exchange must have paid-up charter capital of at least 5,000 BCVs, with 3,000 BCVs reserved in a separate account at a commercial bank in Uzbekistan.
Compliance implications for foreign firms
The proposed penalties would extend the practical reach of Uzbekistan’s crypto-asset supervision beyond locally licensed businesses. Foreign companies that market services to Uzbek residents or process transactions connected to the country may face greater pressure to assess whether their activities require local authorisation.
The draft also places compliance obligations at the centre of enforcement. A firm could face a significant fine not only for operating without a licence but also for failing to safeguard personal data, maintain required records or implement controls addressing money laundering and terrorist financing risks.
For crypto exchanges, custodians and other virtual-asset businesses, the proposal highlights the importance of customer-location controls, sanctions and transaction monitoring, record retention, advertising review and procedures for responding to regulatory requests.
Uzbekistan has previously taken action against overseas platforms accused of serving local customers without the necessary authorisation. In January 2024, NAPP announced a fine against Binance for providing services to Uzbek citizens without a licence and reminded residents that crypto-asset purchases, sales and exchanges must be conducted through national service providers.
The latest draft would create a more detailed system for calculating, imposing and challenging penalties against foreign entities. Until the regulations are formally approved, their final wording, implementation date and application to particular business models remain uncertain. Nevertheless, the proposal signals that NAPP intends to combine licensing enforcement with stronger controls over financial crime, data protection and crypto-asset marketing.