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Turkmenistan

Retail_Trading_Status

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Analysis ID
#266
Version
Archived
Created
2025-04-13 08:01
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Live

Executive Summary

The retail cryptocurrency trading status in Turkmenistan is in a 'Gray-Zone' due to the lack of explicit laws either permitting or prohibiting it. The Central Bank of Turkmenistan has not issued any public statements regarding cryptocurrencies. Key impediments include strict foreign currency controls and the absence of regulated domestic exchanges. Existing AML laws could be interpreted to restrict crypto transactions, and while some sources suggest buying Bitcoin is technically legal, the ambiguity persists due to the lack of clear legislation.

Key Pillars

  • Primary regulator: The Central Bank of Turkmenistan has not issued any public statements clarifying its stance on cryptocurrencies.
  • Core compliance requirements: The Law on Counteracting Legalization of Proceeds from Crime, Financing of Terrorism, and Financing the Proliferation of Weapons of Mass Destruction mandates monitoring of suspicious transactions.
  • There are no specific licensing or registration requirements for cryptocurrency exchanges or related activities.

Landmark Laws

  • "Concept for the Development of the Digital Economy for 2019–2025": Focuses on broader digitalization but does not address private cryptocurrencies.
  • Law on Counteracting Legalization of Proceeds from Crime, Financing of Terrorism, and Financing the Proliferation of Weapons of Mass Destruction [20]: Mandates monitoring of suspicious transactions but does not specifically mention cryptocurrencies.

Considerations

  • Legal classification of crypto assets is unclear.
  • Strict foreign currency controls limit access to funds for cryptocurrency purchases.
  • Lack of regulated domestic exchanges hinders participation.
  • Existing laws on currency regulation and AML could be interpreted to restrict crypto transactions.

Notes

  • There is a significant lack of information regarding cryptocurrencies in Turkmenistan, and not even a statement regarding the stance of the country’s central bank could be found [11].
  • Some sources suggest buying Bitcoin is technically legal [5], but this assessment seems based on the absence of an explicit ban rather than permissive legislation.
  • FATF report notes the lack of possibility to top-up crypto-purses inside the country [9].

Detailed Explanation

The legal landscape for retail cryptocurrency trading in Turkmenistan exists in a 'Gray-Zone.' This classification stems from the absence of explicit laws either permitting or prohibiting cryptocurrency activities for individual citizens and residents. The Central Bank of Turkmenistan has not issued any official statements clarifying its stance on cryptocurrencies. While Turkmenistan is pursuing the "Concept for the Development of the Digital Economy for 2019–2025" [16], this initiative focuses on broader digitalization efforts and does not specifically address private cryptocurrencies.

A significant impediment to cryptocurrency adoption is the strict foreign currency controls enforced by the Turkmen government. Cryptocurrency purchases reportedly require U.S. dollars, but access to foreign currency is heavily restricted for citizens [3, 4, 6, 7]. This limitation makes it exceedingly difficult for ordinary citizens to acquire the necessary funds for cryptocurrency investments. The government's control over the financial system and foreign exchange indirectly restricts participation, even without a direct ban on holding cryptocurrencies. The absence of regulated domestic exchanges, coupled with challenges in accessing foreign currency and international platforms, creates a restrictive environment. A FATF report highlights the impossibility of topping up crypto purses inside the country [9].

Existing laws related to currency regulation, payment systems, and anti-money laundering (AML) could be interpreted to restrict cryptocurrency transactions, even in the absence of specific cryptocurrency legislation [20]. The Law on Counteracting Legalization of Proceeds from Crime, Financing of Terrorism, and Financing the Proliferation of Weapons of Mass Destruction mandates monitoring of suspicious transactions but makes no specific mention of cryptocurrencies [20].

While some sources suggest that buying Bitcoin is technically legal [5], they acknowledge the lack of regulation and potential restrictions imposed by banks. This assessment appears to be based on the absence of an explicit ban rather than any permissive legislation. The overwhelming evidence indicates a lack of clear legal status, coupled with substantial practical and systemic barriers due to the state's tight control over finance and foreign exchange. The Freeman Law group states that "Turkmenistan has not released any concrete information regarding its cryptocurrency currencies' legal status. [...] Therefore, the legal status of cryptocurrency in Turkmenistan is controversial." [3]. In September 2018, Cointelegraph reported that "in Turkmenistan digital currencies can only be bought in foreign currency (U.S. dollars). Moreover, the government has been actively limiting access to foreign currency for local companies and citizens [...] Thus, it makes it more difficult for people to hold digital currencies." [3, 7]

Summary Points

Retail Cryptocurrency Trading Status in Turkmenistan: Regulatory Analysis

I. Overall Regulatory Status:

  • Gray-Zone: The legal status of retail cryptocurrency trading (buying, selling, holding) for individual citizens and residents is ambiguous and lacks specific regulatory clarity.

II. Key Regulatory Bodies and Their Roles:

  • Central Bank of Turkmenistan:
    • Has not issued any public statements clarifying its stance on cryptocurrencies.
    • Plays a significant role in controlling foreign currency access.
  • Government of Turkmenistan:
    • Imposes strict foreign currency controls, limiting citizens' access to USD, which is often required for cryptocurrency purchases.
    • Pursuing a "Concept for the Development of the Digital Economy for 2019–2025," but its impact on private cryptocurrencies is unclear.

III. Important Legislation and Regulations:

  • Lack of Specific Cryptocurrency Legislation: No specific laws govern cryptocurrencies, their trading, or related activities like mining.
  • Existing Laws Potentially Applicable:
    • Laws on currency regulation and payment systems could be interpreted to restrict cryptocurrency transactions.
    • Law on Counteracting Legalization of Proceeds from Crime, Financing of Terrorism, and Financing the Proliferation of Weapons of Mass Destruction: Mandates monitoring of suspicious transactions but doesn't explicitly mention cryptocurrencies.

IV. Requirements for Compliance (Indirect):

  • KYC/AML: While not explicitly stated for crypto, general AML laws exist and could be applied.
  • Foreign Currency Regulations: Strict adherence to government regulations regarding access to and use of foreign currency is crucial for any cryptocurrency-related activity.

V. Notable Restrictions or Limitations:

  • Strict Foreign Currency Controls: Limits citizens' ability to acquire the necessary funds (USD) to purchase cryptocurrencies.
  • Lack of Regulated Domestic Exchanges: Absence of local, regulated exchanges makes participation difficult.
  • Difficulty Accessing International Platforms: Government control over the financial system and foreign exchange hinders access to international cryptocurrency platforms.
  • Limited Possibility to Top-Up Crypto-Purses: FATF report notes the lack of possibility to top-up crypto-purses inside the country.

VI. Recent Developments or Changes:

  • No Significant Changes: The regulatory environment remains largely unchanged, with no new laws or official statements clarifying the status of cryptocurrencies.
  • Digital Economy Initiative: While the government is pursuing digitalization, its impact on private cryptocurrencies remains to be seen.

Full Analysis Report

Report: Retail Cryptocurrency Trading Status in Turkmenistan

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. Detailed Narrative Explanation:

The legal status of retail cryptocurrency trading (buying, selling, holding) for individual citizens and residents in Turkmenistan is ambiguous and lacks specific regulatory clarity, placing it in a 'Gray-Zone'. There is no explicit law or official statement from the Central Bank of Turkmenistan or other government bodies that definitively permits or bans cryptocurrency activities for individuals.

However, several factors create significant practical barriers and legal uncertainties:

  • Lack of Official Recognition and Regulation: Turkmenistan has not released any concrete information regarding the legal status of virtual currencies. No specific laws govern cryptocurrencies, their trading, or related activities like mining [3, 7, 11]. The Central Bank of Turkmenistan has not issued public statements clarifying its stance on cryptocurrencies [11]. While the country is pursuing a "Concept for the Development of the Digital Economy for 2019–2025" [16], this focuses on broader digitalization and does not appear to address private cryptocurrencies.
  • Strict Foreign Currency Controls: A major practical impediment is the requirement to purchase cryptocurrencies using foreign currency (specifically U.S. dollars, according to some reports) [3, 4, 6, 7]. The Turkmen government imposes severe restrictions on citizens' access to and use of foreign currency, limiting the amounts individuals can purchase or withdraw [3, 4, 7]. These controls make acquiring the necessary funds to buy cryptocurrencies extremely difficult for ordinary citizens.
  • Implicit Restrictions via Financial System: While not an explicit ban on holding crypto, the government's control over the financial system and foreign exchange effectively hinders participation. The lack of regulated domestic exchanges and the difficulty in accessing foreign currency or international platforms create a prohibitive environment. A FATF report notes the lack of possibility to top-up crypto-purses inside the country [9].
  • General Legal Framework: Existing laws on currency regulation, payment systems, and potentially anti-money laundering (AML) could be interpreted to restrict or penalize cryptocurrency transactions, even without specific crypto legislation [20]. The Law on Counteracting Legalization of Proceeds from Crime, Financing of Terrorism, and Financing the Proliferation of Weapons of Mass Destruction mandates monitoring of suspicious transactions but doesn't explicitly mention cryptocurrencies [20].

Some sources suggest buying Bitcoin is technically legal [5], but acknowledge the lack of regulation and potential restrictions from banks. However, this assessment seems based on the absence of an explicit ban rather than permissive legislation. The overwhelming evidence points to a lack of clear legal status combined with significant practical and systemic barriers imposed by the state's tight control over finance and foreign exchange. This ambiguity and the indirect restrictions justify the 'Gray-Zone' classification.

3. Relevant Text Excerpts:

  • Freeman Law: "Turkmenistan has not released any concrete information regarding its cryptocurrency currencies' legal status. [...] Therefore, the legal status of cryptocurrency in Turkmenistan is controversial." [3]
  • Freeman Law / Cointelegraph (2018): "Also, it's known that in Turkmenistan digital currencies can only be bought in foreign currency (U.S. dollars). Moreover, the government has been actively limiting access to foreign currency for local companies and citizens [...] Thus, it makes it more difficult for people to hold digital currencies." [3, 7]
  • Fideum (Aug 2024): "Crypto has little penetration in Turkmenistan, predominantly because digital currencies can only be bought in foreign currencies, which the government is limiting access to - so crypto is impacted indirectly." [4]
  • Proelium Law LLP / Cryptocurrency Regulation Tracker: "There's no concrete information regarding virtual currencies' legal status in Turkmenistan. Cryptocurrency is limited to purchase in foreign currency, which is hard to get a hold of due to Government limiting access to foreign currency." [6, 2]
  • Invezz (Feb 2025): "Yes, buying Bitcoin is legal in Turkmenistan. You can safely buy and sell cryptocurrency using a Turkmen crypto exchange. However, many cryptocurrency exchanges aren't regulated in Turkmenistan, as the legislation has yet to catch up with the reality of the crypto market. In addition, there can be limitations on how you fund your purchase." [5] (Note: This source claims legality but acknowledges lack of regulation and limitations, reflecting the ambiguity).
  • FATF (Mutual Evaluation Report): Mentions "...lack of possibility to top-up crypto-purses inside the country." [9]
  • Traders of Crypto: "The country of Turkmenistan, located in Central Asian, seems to have a significant lack of information regarding cryptocurrencies. When we google cryptocurrencies in Turkmenistan or use of Bitcoin in Turkmenistan, not a lot of concrete information regarding their legal status or regulation shows up in the results. Not even a statement regarding the stance of the country’s central bank could be found." [11]

4. Source URLs:

  • [2] Cryptocurrency Regulation Tracker: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJqugexnbRAutnE6SWB7CObr7hAbcNfW_JKvnlQ240iYiTX7a56sMNdE8UScxcMOCtYBSd18SObFV6bM8Ps6DAQJVfa32TtQGBtZdYYoO41Y42uqVXXRqvQrbPjt66VWQezd5UNpG0hzZYekmgycr9b
  • [3] Freeman Law - Turkmenistan & Cryptocurrency: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJG6gFCbtSXDoOW_0BpbxEyk77C4CRRYXbNlTytJG3N838YdrJfSpBBL4wgMpb8CN_JKMOzKzJhuck8r8RT4kx3wq2mP6JXIcVIM70I9u92ZAGJ5RcT4YccExGFd-C0QynLKnnSs9Kq1vs=
  • [4] Fideum - Crypto regulations around the world: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIPkl-zL80Wzcidyjefe9lPWy6anzKx6-bdhrrwaFZd2ODBuOpuT55WXV50ri7fBJUdxASM8CkoW-hmUQvPXikesqcRNooJWKTewg_nMO5_Yw7obL8RM7bp3Wwpw98RCrUIiLLtTp-6PJtSllf9C42Qaw1e0ow=
  • [5] Invezz - 7 Best Exchanges to Buy Bitcoin in Turkmenistan 2025: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIpuTc9kRyayNryDXdlSa7oCuz1KHjO450s0_sibI8tFoyrXPH7eoiP3g34R1r239ljQ7_HOq2gzHzOLQwkLWAdj8Q3YIDDRVvkBS8ekl-ehihZcUawXZgCXDpycVpSozGfgMfdrdvGxMbnL8_MNGNdQYSFmsnnOxv8ONI=
  • [6] Proelium Law LLP - Turkmenistan General Information: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALN0sOtybNLMXBDBtgEvt2YkaYQzuMaunfzbs-Ua1l_miR8iPaojejgxNVwGdRxB9f6DmZEL_KHlPY2zXjNUWocQR5-6uHvbMeap_K_xKq_BI7H-_1O7KfwZzOWG9Rzylk2MhPSs8rwulJTSEnFGyg=
  • [7] Cointelegraph (Sep 2018) - How Cryptocurrencies Are Regulated in Central Asia: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALtelVOrAHgPUg12xWCvQTVRF_jfiamJmCfOUhXJvj_ycSykon298JU07ylkCGHiLKgHTaYpO1laV3YO9odfiH5crB9L-OMfx5OCg9TTj0fB0OHtXO3sIXx_onJrfXBjCqXEdb7c57XCYGTwXc-w4ERzCglXG6RJospbGxBgXzecF8LISk8jsCK5twUY_FpFKTsfj8I7LqQXPaWE-dfKanC4rxFtbg=
  • [9] FATF - Mutual Evaluation Report of Turkmenistan: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIXLm-qOuslDhUMXUWwKtmF52m-l6klprdCh_1kiGRcyuM_dpKBOKG5t_KaDhEaVxyDUUFy1EvrKqYJ_2UHtHn0l76x_PvRe8yt8QJfKhczCuaGPtBrjhY242qi0IWt2qeBpijAclqDOVp8JEUlNoTQSdjD48RrU9mGPl0yLq4JwySOopfSLfG6SzK0YUKPssLY07xwc7K9s0m-TYrW4E7kWAWkeG6SGIx30MRYpw==
  • [11] Traders of Crypto - How to Buy Cryptocurrency in Turkmenistan: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKfMqpTRvhdLiVsHfr8oR8azAXf4XlwOBTvMU4hbY0HK01THZyCUvLXsLWl_mTzhGQRigKL4y5x48TSa-vQmi_lHrzxw2DJg8E901HEa_hgKXmaN9sRdrqXqn__Jn9br9OpgH-AQwHR5Ww=
  • [16] MDPI - Digitalization...and Regulations for Modern Economic Development in Turkmenistan: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJE9S1mtyQDMed5w_-xFM9Ms-N5NyeJDZ3Nqc4HXKuoh5roBJV26UdyuhWUU626lYA6kLdxI2Cmz9ECKp32o_aiwqv4MrP6BmE3E0DHWbSdm1aKl5LV4zl3Xn6WMvyI4Q==
  • [20] Turkmenistan Law - On Counteracting Legalization of Proceeds from Crime...: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALwXfa5zUUMAstOuXzuyPWVzNiXhxYeNSceY0kxseu-ggVQyc72O2cjYrZVoRsjbK06qvZ3_G7Sc9-IyzNtFGkk0JL6jmXzl0eISfeNjy1bvkL_Z2V1qXgf8LnHuUs1widvuOU2ybIg

Web Sources (12)

Sources discovered via web search grounding

Search queries used (7)
  • Is cryptocurrency trading legal for individuals in Turkmenistan?
  • Turkmenistan central bank cryptocurrency statement
  • Turkmenistan digital currency law
  • cryptocurrency regulation Turkmenistan
  • retail crypto trading Turkmenistan restrictions
  • закон о криптовалюте Туркменистан
  • Центральный банк Туркменистана криптовалюта
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