Back to Analyses

Turkmenistan

Retail_Trading_Status

Gray-Zone High Confidence
Edit
Analysis ID
#809
Version
Latest
Created
2025-12-12 05:20
Workflow Stage
Step 1

Executive Summary

As of December 12, 2025, Turkmenistan is in a transitional regulatory phase. While the government historically enforced a de facto ban on cryptocurrency activities, President Serdar Berdimuhamedov signed the landmark 'Law on Virtual Assets' on November 28, 2025. This legislation, which formally legalizes and regulates cryptocurrency mining and exchange operations under strict state control, is scheduled to enter into force on January 1, 2026. Until that date, no active licensing regime exists, and the sector remains technically unregulated but subject to strict oversight and previous prohibition enforcement practices.

Key Pillars

Central Bank of Turkmenistan (CBT) (Primary Regulator & Licensing Authority)
Mandatory State Registration for Miners (Effective Jan 1, 2026)
Licensing for Virtual Asset Service Providers (VASPs) (Effective Jan 1, 2026)
Strict KYC/AML Compliance aligned with FATF standards
Prohibition on Crypto Payments (Assets are not legal tender)

Landmark Laws

Law on Virtual Assets (Law signed Nov 28, 2025) - Enacted: 2025-11-28
- Comprehensive framework legalizing mining and exchanges effective Jan 1, 2026. Defines virtual assets as property but not legal tender. Requires CBT licensing for exchanges and registration for miners. Bans 'hidden' mining and the use of crypto for payments.

Law on Combating Money Laundering and Terrorist Financing (AML/CFT Law) - Enacted: 2009-01-01
- General AML framework that applies to financial monitoring; updated to include virtual assets under the new 2025 legislation.
- Source

Considerations

Transition Period: The new law is signed but not effective until Jan 1, 2026; current trading status is legally ambiguous.
State Control: The Central Bank has authority to operate its own blockchain and strictly control all VASP activities.
Banking Ban: Traditional credit institutions are explicitly prohibited from offering crypto services.
Payment Ban: Crypto cannot be used as a means of payment for goods or services within Turkmenistan.
Advertising Restrictions: Strict rules prevent advertising crypto as a 'get rich quick' scheme or using national symbols.

Notes

The status is classified as 'Gray-Zone' solely because the legalization law (signed Nov 2025) does not become effective until Jan 1, 2026. On that date, the status will shift to 'Allowed-Regulated'. The environment is characterized by extreme state control, and 'legalization' should not be interpreted as liberalization; it is a move to bring the black market under state surveillance.

Remaining Uncertainties

  • Specific capital requirements for exchange licenses are not yet public.
  • Tax rates for crypto mining and trading profits have not been detailed in the initial reports.
  • The practical process for 'registering' mining equipment with the Central Bank is yet to be tested.

Detailed Explanation

As of December 12, 2025, Turkmenistan is classified in a Gray-Zone regulatory status, representing a transitional phase between historical prohibition and impending formal regulation. The country has historically enforced a de facto ban on cryptocurrency activities, but this is set to change with the landmark 'Law on Virtual Assets' signed by President Serdar Berdimuhamedov on November 28, 2025. This law, however, does not enter into force until January 1, 2026, creating a period of legal ambiguity where the sector remains technically unregulated but subject to the state's strict oversight and previous enforcement practices against prohibition. Upon the law's effective date, the status is expected to shift to 'Allowed-Regulated', though this legalization is designed for extreme state control and surveillance rather than market liberalization. The regulatory framework established by the new law is comprehensive and highly restrictive. The Central Bank of Turkmenistan (CBT) is designated as the primary regulator and licensing authority. The law formally legalizes and regulates cryptocurrency mining and exchange operations, defining virtual assets as property but explicitly not as legal tender. Two key pillars take effect on January 1, 2026: mandatory state registration for cryptocurrency miners and a licensing regime for Virtual Asset Service Providers (VASPs), such as exchanges. All licensed entities must adhere to strict Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance standards, which are aligned with FATF recommendations and underpinned by the existing 'Law on Combating Money Laundering and Terrorist Financing' enacted on January 1, 2009, which has been updated to encompass virtual assets. The environment is characterized by significant restrictions that underscore the state's desire for total control. A core prohibition bans the use of cryptocurrency as a means of payment for goods and services within Turkmenistan, reinforcing that it is not legal tender. Furthermore, traditional credit institutions are explicitly barred from offering any crypto-related services. The law also bans 'hidden' mining operations and imposes strict advertising rules to prevent the promotion of cryptocurrency as a 'get rich quick' scheme or the use of national symbols in such promotions. Notably, the Central Bank retains the authority to operate its own blockchain, emphasizing the model of state-dominated oversight that will define Turkmenistan's regulated crypto market from 2026 onward.

Summary Points

I. Regulatory Status
* As of December 12, 2025, the status is Gray-Zone.
* This is a transitional phase due to a signed but not-yet-effective law.
* Historical de facto ban on cryptocurrency activities is still the prevailing environment.
* Status will shift to Allowed-Regulated on January 1, 2026, when new legislation takes effect.
* The legalization is for strict state control and surveillance, not market liberalization.

II. Key Regulatory Bodies
* Central Bank of Turkmenistan (CBT)
* Primary regulator and licensing authority for the virtual asset sector.
* Has authority to operate its own blockchain.
* Will oversee mandatory registration for miners and licensing for exchanges from January 1, 2026.

III. Important Legislation
* Law on Virtual Assets (Law signed November 28, 2025)
* Landmark comprehensive framework that legalizes and regulates cryptocurrency mining and exchange operations.
* Scheduled to enter into force on January 1, 2026.
* Defines virtual assets as property but not as legal tender.
* Establishes CBT licensing for exchanges and state registration for miners.
* Explicitly bans 'hidden' mining and the use of crypto for payments.
* Law on Combating Money Laundering and Terrorist Financing (AML/CFT Law) (Enacted: January 1, 2009)
* General AML framework applicable to financial monitoring.
* Has been updated to include virtual assets under the new 2025 legislation.

IV. Compliance Requirements
* Mandatory State Registration for Miners (Effective Jan 1, 2026).
* Licensing for Virtual Asset Service Providers (VASPs) such as exchanges (Effective Jan 1, 2026).
* Strict KYC/AML Compliance for all licensed entities, aligned with FATF standards.

V. Notable Restrictions or Limitations
* Payment Ban: Cryptocurrency cannot be used as a means of payment for goods or services within Turkmenistan.
* Banking Ban: Traditional credit institutions are explicitly prohibited from offering crypto services.
* Advertising Restrictions: Strict rules prevent advertising crypto as a 'get rich quick' scheme or using national symbols.
* Mining Ban: The law prohibits 'hidden' mining operations.
* State Control Model: The regulatory framework is designed for extreme state oversight, not a free market.

VI. Recent Developments or Notes
* The Law on Virtual Assets was signed by President Serdar Berdimuhamedov on November 28, 2025, but is not yet in force.
* Until January 1, 2026, no active licensing regime exists, and the sector remains in a technically unregulated but closely watched gray zone.
* The transition marks a shift from prohibition to a highly controlled, state-surveilled regulatory environment.

Full Analysis Report

As of December 2025, Turkmenistan's cryptocurrency landscape is undergoing a critical shift from a restrictive, gray-market environment to a highly regulated state-controlled system. Historically, the country maintained a hostile stance toward digital assets, with authorities conducting raids on mining operations and enforcing a de facto ban to protect the national currency (Manat) and control capital flows. There was no specific legislation, but 'economic safety' measures were used to suppress activity.

On November 28, 2025, President Serdar Berdimuhamedov signed the 'Law on Virtual Assets,' marking the country's first formal recognition of the industry. This law, effective January 1, 2026, establishes the Central Bank of Turkmenistan (CBT) as the primary regulator. It mandates that all cryptocurrency exchanges and custodial services obtain a license and adhere to strict Know Your Customer (KYC) and Anti-Money Laundering (AML) protocols. The law explicitly categorizes virtual assets as 'property' subject to civil law but categorically denies them status as legal tender or foreign currency.

Mining is a major focus of the new framework. Both individual entrepreneurs and legal entities will be permitted to mine, provided they register with the CBT. 'Hidden' or covert mining is strictly criminalized. The government views regulated mining as a potential revenue stream, leveraging the country's energy resources, but retains the right to authorize or operate the underlying distributed ledger technology itself, hinting at a preference for permissioned, state-monitored blockchains over public networks.

Despite the legalization, the operational environment for retail traders remains restrictive. The law prohibits the use of cryptocurrency for payments within the country and bans traditional banks from offering crypto services, effectively ring-fencing the crypto sector from the conventional financial system. Furthermore, advertising is heavily regulated; companies cannot use national symbols or promise guaranteed returns. Until the law's effective date in January 2026, the status remains 'Gray-Zone' as the licensing mechanisms are not yet active, and previous enforcement attitudes may still prevail.

Source Evidence

Primary and secondary sources cited in this analysis

"The state media said President Serdar Berdymukhamedov signed the 'Law on Virtual Assets' on Nov. 28 and it will take effect on Jan. 1, 2026."

2023-12-04

"Turkmenistan has a strong legal framework for combating money laundering... countering the use of virtual assets for criminal purposes."

"The new law will take effect on January 1, 2026... Credit institutions are banned from offering crypto services under the new framework."

"Miners and exchanges must register or be licensed through the Central Bank of Turkmenistan... Cryptocurrencies will not be legal tender."

Web Sources (12)

Sources discovered via web search grounding

Search queries used (5)
  • Turkmenistan crypto mining laws
  • Turkmenistan cryptocurrency regulation status 2024 2025
  • buying bitcoin in Turkmenistan legality
  • Turkmenistan FATF mutual evaluation report virtual assets
  • Central Bank of Turkmenistan crypto ban circular
lbank.com

https://www.lbank.com/id/how-to-buy-news/article/scratch-3-9019

coinlaw.io

https://coinlaw.io/turkmenistan-legalizes-crypto-mining-trading-2026/

fergana.agency

https://en.fergana.agency/news/143381/

crowdfundinsider.com

https://www.crowdfundinsider.com/2025/12/256216-turkmenistan-legalises-crypto-mining-sets-licensing-for-exchanges-under-new-law/

cryptodaily.co.uk

https://cryptodaily.co.uk/2025/12/turkmenistan-legalises-cryptocurrencies-from-2026

bravenewcoin.com

https://bravenewcoin.com/insights/turkmenistan-legalizes-crypto-trading-under-tight-state-control-from-2026

cryptonews.com

https://cryptonews.com/news/turkmenistan-legalizes-crypto-law-2026/

coinjournal.net

https://coinjournal.net/news/turkmenistan-joins-global-crypto-regulation-push-with-sweeping-new-digital-asset-law/

cryptopolitan.com

https://www.cryptopolitan.com/turkmenistan-legalize-crypto-mining-trading/

quasa.io

https://quasa.io/media/turkmenistan-breaks-new-ground-legalizes-cryptocurrency-mining-and-exchanges

odaily.news

https://www.odaily.news/en/newsflash/458663

chaincatcher.com

https://www.chaincatcher.com/en/article/2224669

Reviews

No reviews yet

Submit Review

Challenge: Disagree with the analysis | Approval: Confirm it's correct | Refinement: Suggest improvements