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Uzbekistan

Retail_Trading_Status

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Analysis ID
#229
Version
Archived
Created
2025-04-13 07:23
Workflow Stage
Live

Executive Summary

Uzbekistan's retail crypto trading is in a 'Gray-Zone,' regulated by the National Agency of Perspective Projects (NAPP) but with restrictions on residents' purchasing activities. Since January 1, 2023, residents can only transact through domestically licensed Crypto Asset Service Providers (CASPs), with foreign exchanges blocked. AML/KYC requirements are strict for CASPs, and crypto transactions are tax-exempt. The exact rules around buying crypto are ambiguous, contributing to the 'Gray-Zone' status.

Key Pillars

  • Primary Regulator: The National Agency of Perspective Projects (NAPP) is the primary regulator, reporting directly to the President, and is responsible for licensing CASPs, introducing regulations, and ensuring compliance.
  • Core Compliance: Licensed CASPs are subject to AML/CFT regulations, aligning with FATF recommendations. This includes mandatory KYC procedures, customer due diligence, and transaction monitoring. Anonymous transactions are prohibited.
  • Licensing: Crypto Asset Service Providers (CASPs), including crypto exchanges, crypto stores, crypto depositories, and mining pools, must be legally registered in Uzbekistan and hold the necessary licenses to operate.

Landmark Laws

N/A (No specific act is named, however, regulations by NAPP are mentioned regarding licensing of Crypto Asset Service Providers (CASPs) and restrictions on residents).

Considerations

  • Crypto-assets are regulated but not legal tender.
  • Crypto transactions are exempt from taxation for individuals and legal entities.
  • NAPP has issued warnings to foreign exchanges operating without licenses.
  • Residents are restricted to using domestic platforms for crypto transactions (using the national currency, Som).

Notes

  • Restrictions on purchasing cryptocurrency existed around 2019-2022 where residents were prohibited from purchasing but allowed to sell. Post-January 1, 2023, some sources indicate residents can 'buy, sell, and exchange' through domestic CASPs, but other sources reiterate the restriction on buying, highlighting ambiguity.
  • NAPP has blocked access to international exchanges operating without licenses.
  • All cryptocurrency transactions, whether conducted by individuals or legal entities, are exempt from taxation in Uzbekistan.

Detailed Explanation

The retail cryptocurrency trading landscape in Uzbekistan operates within a 'Gray-Zone' due to specific restrictions imposed on residents. While crypto-assets are officially recognized and regulated, they are not considered legal tender. The primary regulatory body is the National Agency of Perspective Projects (NAPP), which reports directly to the President of Uzbekistan and is responsible for licensing Crypto Asset Service Providers (CASPs). These CASPs include crypto exchanges, crypto stores, crypto depositories, and mining pools, all of which must be legally registered in Uzbekistan, host servers locally, and adhere to specific regulations. Since January 1, 2023, a key restriction has been placed on residents, limiting them to conducting crypto-asset transactions exclusively through domestically licensed CASPs, using the national currency (Som). Access to many international platforms has been blocked by regulators for operating without a local license. Historically, and according to some sources reflecting regulations implemented around 2019-2022, residents were prohibited from purchasing cryptocurrencies through licensed domestic exchanges but were allowed to sell crypto-assets they already possessed. Newer sources (post-January 1, 2023 implementation) state residents can 'buy, sell, and exchange' through domestic CASPs. This ambiguity or potential evolution in rules contributes to the gray zone status. Even if buying is technically permitted now through licensed domestic providers, the historical context and potential remaining complexities mean it's not a straightforward 'allowed' situation comparable to many other regulated markets.

Regulations primarily focus on the turnover (transactions) of crypto-assets; holding previously acquired crypto assets does not appear to be explicitly banned. Licensed CASPs are subject to stringent Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations, aligned with Financial Action Task Force (FATF) recommendations, including mandatory Know Your Customer (KYC) procedures, customer due diligence, and transaction monitoring. Anonymous transactions are prohibited. Cryptocurrency transactions are exempt from taxation for both individuals and legal entities, and income from these operations is not included in the tax base. NAPP has issued warnings to foreign exchanges operating without licenses and has blocked access to unlicensed platforms serving Uzbek residents. In summary, the regulatory framework creates a complex 'Gray-Zone' due to restrictions on how and if residents can purchase cryptocurrencies and the requirement to use only domestic platforms.

Summary Points

Here's a bullet-point summary of the retail cryptocurrency trading status in Uzbekistan, based on the provided report:

Retail Cryptocurrency Trading Status in Uzbekistan: Gray-Zone

  • Overall Status: Retail cryptocurrency trading in Uzbekistan exists in a "Gray-Zone" – not fully allowed nor completely banned, due to restrictions on purchasing and platform usage.

1. Regulatory Bodies and Roles:

  • National Agency of Perspective Projects (NAPP):
    • Primary regulator for the crypto market in Uzbekistan.
    • Reports directly to the President.
    • Responsible for:
      • Licensing Crypto Asset Service Providers (CASPs).
      • Introducing new rules and regulations.
      • Ensuring compliance within the sector.

2. Key Legislation and Regulations:

  • Recognition of Crypto-Assets: Uzbekistan officially recognizes and regulates crypto-assets, but they are not legal tender.
  • Licensing Requirement: Crypto Asset Service Providers (CASPs) must be licensed by NAPP to operate legally.
  • Local Presence: Licensed CASPs must:
    • Operate within Uzbekistan.
    • Host servers locally.
    • Adhere to specific rules.

3. Requirements for Compliance:

  • AML/KYC: Licensed CASPs are subject to strict Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations.
    • Mandatory Know Your Customer (KYC) procedures.
    • Customer due diligence.
    • Transaction monitoring.
    • Aligned with FATF recommendations.
  • No Anonymous Transactions: Anonymous crypto transactions are prohibited.

4. Notable Restrictions and Limitations:

  • Restricted to Domestic Platforms:
    • Since January 1, 2023, residents of Uzbekistan are generally only permitted to conduct crypto-asset transactions through domestically licensed CASPs.
    • Using foreign exchanges is restricted.
    • Access to many international platforms has been blocked for operating without a local license.
  • "Buy vs. Sell" Nuance (Potential Ambiguity):
    • Historically (around 2019-2022), residents were prohibited from purchasing cryptocurrencies through licensed domestic exchanges, but allowed to sell crypto-assets they already possessed.
    • Some newer sources (post-January 1, 2023) state residents can "buy, sell, and exchange" through domestic CASPs.
    • The requirement to use only domestic platforms for these transactions (using the national currency, Som) is a significant restriction.
  • Holding Crypto: Holding previously acquired crypto assets does not appear to be explicitly banned.

5. Recent Developments and Changes:

  • Restriction to Domestic Platforms (January 1, 2023): Residents are now primarily limited to using domestically licensed CASPs for crypto transactions.
  • Blocking of Foreign Exchanges: NAPP has blocked access to international exchanges operating without licenses.

6. Taxation:

  • Tax Exemption: Transactions involving crypto-assets are currently exempt from taxation for both individuals and legal entities in Uzbekistan. Income from these operations is not included in the tax base.

Full Analysis Report

Okay, here is the comprehensive report on the current status of retail cryptocurrency trading in Uzbekistan, following the specified structure and guidelines.

Report: Retail Cryptocurrency Trading Status in Uzbekistan

Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued)

1. Identified Status:

Gray-Zone

2. Narrative Explanation:

The status of retail cryptocurrency trading for citizens and residents of Uzbekistan is best described as a Gray-Zone. While Uzbekistan has established a formal regulatory framework for crypto-assets and related service providers, significant restrictions apply specifically to the activities permitted for its residents, creating a situation that is neither fully allowed nor completely banned, and doesn't fit neatly into the Allowed-Regulated category due to limitations on purchasing.

  • Regulatory Framework: Uzbekistan officially recognizes and regulates crypto-assets, although they are not legal tender [2, 4, 17]. The primary regulator is the National Agency of Perspective Projects (NAPP), which reports directly to the President [5, 17, 19]. NAPP is responsible for licensing Crypto Asset Service Providers (CASPs), including crypto exchanges, crypto stores, crypto depositories, and mining pools [2, 4, 17]. These licensed entities must operate within Uzbekistan, host servers locally, and adhere to specific rules [6, 10, 13].
  • Restrictions on Residents: A key aspect creating the gray zone is the specific limitation imposed on residents. Since January 1, 2023, residents of Uzbekistan are generally only permitted to conduct crypto-asset transactions (buying, selling, exchanging) through domestically licensed CASPs [2, 4, 9, 17]. Using foreign exchanges is restricted, and access to many international platforms has been blocked by regulators for operating without a local license [4, 10, 14].
  • The "Buy vs. Sell" Nuance: Historically, and according to some sources reflecting regulations implemented around 2019-2022, there was a significant restriction where residents were prohibited from purchasing cryptocurrencies through licensed domestic exchanges, while they were allowed to sell crypto-assets they already possessed [3, 11, 16]. While some newer sources (post-January 1, 2023 implementation) state residents can "buy, sell, and exchange" through domestic CASPs [2, 7], others reiterate the restriction on buying [3]. This ambiguity or potential evolution in rules contributes to the gray zone status. Even if buying is technically permitted now through licensed domestic providers, the historical context and potential remaining complexities mean it's not a straightforward "allowed" situation comparable to many other regulated markets. The requirement to use only domestic platforms for these transactions (using the national currency, Som) is also a significant restriction [2, 7].
  • Holding Crypto: The regulations primarily focus on the turnover (transactions) of crypto-assets. While direct purchase might be restricted or channeled, holding previously acquired crypto assets does not appear to be explicitly banned.
  • AML/KYC Requirements: Licensed CASPs are subject to strict Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations, aligned with FATF recommendations [2, 5, 18]. This includes mandatory Know Your Customer (KYC) procedures, customer due diligence, and transaction monitoring [2, 4, 7]. Anonymous transactions are prohibited [3].
  • Taxation: Transactions involving crypto-assets are currently exempt from taxation for both individuals and legal entities in Uzbekistan. Income from these operations is not included in the tax base [2, 4, 5, 9, 17].
  • Official Warnings: NAPP has issued warnings to foreign exchanges operating without licenses and has taken action to block access to unlicensed platforms serving Uzbek residents [4, 10].

In summary, while a regulated infrastructure exists, the specific limitations on how and if residents can purchase cryptocurrencies, combined with the restriction to use only domestic platforms, places retail trading in a complex Gray-Zone rather than being simply Allowed-Regulated or Banned.

3. Supporting Excerpts:

  • On Regulation and Domestic Platform Requirement: "(2023-10-05) Starting on January 1st 2023, residents of Uzbekistan can engage in cryptocurrency transactions exclusively through domestic virtual asset service providers (VASPs)." [2]
  • On Restriction to Domestic Platforms: "(2024-04-03) Since January 1, 2023, residents have been permitted to engage in crypto transactions exclusively through domestic CASPs. These CASPs, divided into four categories – crypto exchanges, crypto stores, crypto depositories, and mining pools – must be legally registered in Uzbekistan and hold the necessary licenses to operate." [17]
  • On the "Buy vs. Sell" Restriction (potentially older rule, but highlights complexity): "Under the Rules of crypto-exchange trading, residents of Uzbekistan cannot buy digital currency. They are only allowed to sell crypto assets and tokens. This restriction does not apply to citizens of other countries." [3]
  • Contrasting View (suggesting buying is allowed via domestic VASPs): "(2023-10-05) While residents of Uzbekistan are restricted to buying and selling cryptocurrencies solely through domestic VASPs using the national currency..." [2]
  • On AML/KYC: "(2023-10-05) Anti-money laundering and crypto crime prevention. Internal control rules are established for VASPs, aligning with Financial Action Task Force (FATF) Recommendations and regulating the know-your-customer (KYC) procedures and risk-based approach." [2]
  • On Regulator: "(2024-04-03) The National Agency of Perspective Projects (NAPP), reporting directly to the President of Uzbekistan, serves as the primary regulator for the crypto market. NAPP is responsible for licensing CASPs, introducing new rules and regulations, and ensuring compliance within the sector." [17]
  • On Blocking Foreign Exchanges: "(2022-08-12) Uzbekistan's cryptocurrency regulator has blocked access to international exchanges... The National Agency for Perspective Projects (NAPP)... announced that the exchanges were blocked because they were operating without the licenses they are legally required to obtain." [10]
  • On Tax Exemption: "(2023-10-05) All cryptocurrency transactions, whether conducted by individuals or legal entities, including non-residents, are exempt from taxation in Uzbekistan. The income generated from these operations is not considered part of the taxable base for taxation purposes." [2]

4. Source Links:

  • [2] Elliptic - Uzbekistan Crypto Regulation Summary (Oct 2023): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJap7w4Q7K02VoFEfUE8AKIYiM_7u2vjMlb7oSNB_6D7gaMFYV7pUreqqaCiLjc3zadAR56fwgmfZoJrpUPnXPK_i6v5jkyeNFOlfiQcIU6xALaa1NJi2NyuQF1M4r-F-smy_jMffct (Note: Link redirects via Google API)
  • [3] Unicase Law Firm - Cryptocurrency In Uzbekistan: Legal Or Not?: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJLsjklyRptYeFa51KdUdVqTCW7LAHHIRyJnt3AH1fUzk3tWbQW-pPWWicM9kH0O4lY6v39XCIfoYrNnBwhoJTko85JLOOG-dunMt3J9ZXU98kjvwaRAuFmUQb5mjMeJA0WnplJ1ZgbtwPJhg422dEnGOvhkOUXcMgj41o= (Note: Link redirects via Google API)
  • [4] Crypto Guide Uzbekistan (Praelegal/Heemera): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALV1OSljRjfVoywO1qhXO2Q-SIbQm8xlBq_LZVj9fwejiZX77WYS-mLm-1TAPduXhhC89809tgH6LvAfVhyLOCoxd5qnBuS8OHxfoPBVg== (Note: Link redirects via Google API, original likely at cryptoguide.uz)
  • [5] Prifinance - Cryptocurrency exchange license in Uzbekistan: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKnjZ3Rmf3ZGasLWL6fCmERXbEuBrHs_kcWPuN5SN_heiRPK23mNVhsFCkruKp0xBymVzF7D1BGlamI0rprXcIG_lGW5BVrBM9nC0scJLiniL_L6Lwt4CbZiS_aQB6wU2_Cds1GtxaGBRoVfWlebslrw0U= (Note: Link redirects via Google API)
  • [6] Winfields Law Firm - VASP License Uzbekistan: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJZImqEW7CuxLV_NlosagKoZFl2PSYaRTo610uE16ZpwjALHQLi1QSPZVCvGrQGW5_zZti-n1i3iUP0lBB0xGJx099t1Sdg_iL7FwVoptlE1S2XRtd3q5IRdp_wqt8meYQfZOW_to3w1Rn3iJ_3a5onJ12hxca4hC-zXXcLkuugWibvasd2xF2jU52lQ4tmyQuHdUpiKlqNr9s-4S7jAoMNCJ-8 (Note: Link redirects via Google API)
  • [7] Coincub - Best Crypto Exchange Uzbekistan: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJYszyLg0oC6EV7mExc5L-LNGvl_cLivJrZALUy-DwhmqXIR8B6Y2r5hNX6RlLaIIyotecg8-Ye8URzoAQj5_dxjuBp_3ebde1F_KZPli35Mg1jnSuzz-Qd8slYTJzXnw== (Note: Link redirects via Google API)
  • [9] Deloitte - Digital assets in Central Asia and the Caucasus (Nov 2024): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJtwheo4nnA93rjgqRccsixW7CgyZokL8JgZVmhKZyes-Rfz7YQbA8x3kGFsRsKh3SawDPWX5fX_dk9V5bIMVMPEyZxTmMmamvmAKwhDo6wp7_NkDJOWlhzSaNgytjH_nhyXN7LnsCwPF6Ewqyt7HLXX0Qubt-SjBb_DurKrox-PEPixH0LPZCcona5 (Note: Link redirects via Google API)
  • [10] Eurasianet - Uzbekistan blocks cryptocurrency exchanges (Aug 2022): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJ7tn8p63B3wtd1rbARci7si74up2kh-j8tf-znO9I1u0CRW9ywluXaWtZyvu1N2VSOymysUaW4yAXv9udMWZpsZTD6QlRtEAeC6TvkGiYZtOpHiEfScu2F61oJH1VK55QlWkU3Q4OE3yX3IofHBAH-giwNcn0nEg== (Note: Link redirects via Google API)
  • [11] Bitcoin.com News - Uzbekistan Bans Citizens From Buying Crypto (Dec 2019): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJIrQ3VGiXey4pZ_FqIbZKRH3JH8gqAfQ-dSRBoV15QKuRA6r4Ucu6AiGf7-atiin_beGZqJOn-5EXYWgDsn0blTp993ytzH3uO36elp9xyK4ANERFAQWPAJPTxFSWx7jQJqY6FH8v3Uq0-79_bZ_gkSXrihU_Wx_z4LteuTztUUH_jGkewVcT-knY3q_8v (Note: Link redirects via Google API, reflects older rule)
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  • [14] Remitano Forum - Uzbekistan issues first crypto licenses (Nov 2022): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALX2dOdPRDz2KRBinSKrPWax_RJBAOT_uZvntu5lyoqoXPLujVcqt2l2sXqXYEwtVRbpndzMomZKq7uUYyKSZJHiKVgkYa1cQ_awVN1cX8z3DVGZnSAzLQ1UmZ8ix4ktG0xnKe_zdiYsI5MIBaC9DTgOZ9J2OUaMFbfRsK6ncoT2tUlzJYdgKRA0N92bbxkWRWqlu-vPdcADqNVQcPD4QH3uY9c1pk= (Note: Link redirects via Google API)
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  • [17] Daryo.uz - Uzbekistan's regulatory landscape for crypto assets (Apr 2024): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAL2uAMyQlXPsxkYw73T9wSNLLPn07zPTMF-s6YfBRtazPUM8zljduBIFpkZlDk6yuOeWDHqyBvRN9Aj6tZlm4t2etSpEyBC1WzWOgibFzJw4ggGSNWfNOHgl2dhEcKkMqWpOndsJ2UORi48j6C3v9L36tCg_nuY1PTnMg1aphc4V1pLgi3LAcWx8ETa_jchbh439XxIzbo_lFdIjRykDA== (Note: Link redirects via Google API)
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  • [19] National Agency of Perspective Projects (NAPP) - About Page: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKJwRKfX04ygLa-L5xOPSSsat_xx_6OuWNq08EPQ8m-WFZ02alxxDxLobOC4Sp7gbm5kdmrg5R_hmRoc8NJALU65sT8j697MoITgD00-_a6VyReIThcIg== (Note: Link redirects via Google API, official NAPP site is primary source)

Web Sources (9)

Sources discovered via web search grounding

Search queries used (6)
  • legal status retail cryptocurrency trading Uzbekistan citizens
  • NAPP Uzbekistan crypto regulations for individuals
  • Can Uzbek citizens buy cryptocurrency?
  • Uzbekistan Presidential Decree cryptocurrency retail
  • Uzbekistan crypto exchange license rules
  • AML KYC crypto Uzbekistan

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