Belarus

Presidential Decree No. 8 (2017) initially legalized cryptocurrencies and set a framework for activities like mining, exchange, and token creation in Belarus, but subsequent regulatory actions by Belarusian authorities have narrowed its scope by preapproving only 26 specific cryptocurrencies for processing by cryptobanks, imposing restrictions not present in the original decree.

**Reference (English summary/analysis - finding direct official English text can be challenging):** Many legal firms have published summaries. For example, Sorainen provides a good overview: https://www.sorainen.com/publications/belarus-decree-no-8-on-the-development-of-the-digital-economy/

The Belarusian Agriculture and Food Ministry has opened a public consultation on a new draft law on farms, indicating that the previously referenced regulation (Pd1700008) is likely being updated or replaced.

**No standalone "custodial license"**: Belarus does not issue a specific "digital asset custodial license" in the traditional sense, separate from a broader digital asset service provider license.

**HTP Residency**: The primary requirement to operate as a digital asset custodian (among other services) is to **become a resident of the Hi-Tech Park (HTP)**.

HTP residency grants the right to engage in activities related to digital tokens, including their storage and transfer.

Applicants for HTP residency must submit a business plan, demonstrate a suitable business model, and comply with HTP's internal rules and oversight, including AML/CFT requirements.

**Relevant Provisions in Decree No. 8**: Article 4.2 of Decree No. 8 defines "cryptocurrency exchange operator" and "other operator" as entities engaging in activities like storage, transfer, and exchange of digital signs (tokens). It explicitly states that "storage of tokens on their own accounts for their clients" is an activity permitted for HTP residents.

**Decree No. 8's Stance**: The decree itself **does not explicitly detail strict segregation requirements** in the way traditional financial regulations do (e.g., mandating separate legal entities or specific trust accounts for client funds vs. operational funds).

**Implicit Expectation/Best Practice**: While not explicitly codified in the primary decree, reputable digital asset service providers are expected to employ robust internal controls. Given the HTP's oversight and AML/CFT requirements, ensuring proper accounting and logical segregation of client assets from the firm's own assets would be a strong expectation and potentially an internal HTP guideline or a condition of residency for a particular operator.

**HTP Oversight**: The HTP administration reviews the business operations and internal policies of its residents. It is highly probable that during the application or ongoing supervision, they would require companies to demonstrate adequate risk management and operational controls for safeguarding client assets, which would typically include some form of asset segregation.

**No explicit mandate**: Presidential Decree No. 8 **does not explicitly mandate specific insurance or bonding requirements** for digital asset custodians (HTP residents).

**Industry Practice**: While not legally required, well-established and responsible digital asset custodians often obtain cyber insurance, crime insurance, or other forms of coverage to protect against potential losses due, for example, to hacks, theft, or operational errors. This would be a business decision rather than a regulatory mandate in Belarus.

**No explicit mandate**: Decree No. 8 **does not explicitly mandate the use of cold storage** or any specific technology for safeguarding digital assets.

**Security Expectations**: Custodians are generally expected to implement strong security measures to protect client assets. The choice between hot, warm, or cold storage, multi-signature wallets, hardware security modules (HSMs), etc., is typically left to the operator's discretion, based on their risk assessment and technological capabilities. The HTP's oversight would likely focus on the overall security framework and risk management rather than prescribing specific technological solutions.

**No specific definition**: Belarus **does not have a specific legal definition of a "qualified custodian"** analogous to those found in other jurisdictions (e.g., the SEC's definition in the US for registered investment advisers).

**Functional Equivalent**: Within the Belarusian framework, an HTP resident that is authorized by the HTP administration to perform digital asset storage services for clients effectively *acts as* the qualified custodian. The "qualification" stems from achieving and maintaining HTP residency and adhering to the HTP's supervisory requirements.

As of my last update, there are **no widely reported pending legislative changes specifically targeting digital asset custody** that would significantly alter the existing HTP-centric framework in Belarus. The country has largely maintained its approach under Decree No. 8 since its implementation.

However, digital asset regulations are dynamic globally. The HTP administration might issue internal guidelines or recommendations for its residents, but major legislative overhauls are not publicly anticipated.

**Exclusion from HTP residency:** This is the most significant regulatory action against licensed entities.

**Criminal prosecution:** Against individuals or groups operating illegally (outside HTP's framework), engaging in fraud, or money laundering.

**Regulator Name:** Hi-Tech Park (HTP) Administration

**Entity Targeted:** **WhiteBird LLC** (the Belarusian legal entity associated with the WhiteBIT crypto exchange)

**Violation Type:** Failure to comply with the requirements for Hi-Tech Park residency and the norms of Decree No. 8. While specific details are often not fully disclosed by HTP, such exclusions typically stem from operational deficiencies, non-compliance with AML/CFT standards, or failure to meet the requirements of the special legal regime.

**Penalty Amount:** Loss of HTP residency (effectively, revocation of its operating license in Belarus). No specific monetary fine for the exclusion itself is usually reported.

**Outcome:** WhiteBird LLC was excluded from the HTP. This led to WhiteBIT announcing the cessation of services for residents of Belarus as of March 2024.

HTP official announcement of exclusion (in Belarusian)

WhiteBIT voluntarily exited Belarus in 2022, not as a new announcement

Belarusian tech news coverage (dev.by, in Russian)

**Regulator Name:** Ministry of Internal Affairs (MVD), Investigative Committee of Belarus, Financial Monitoring Department (FMD) of the State Control Committee.

**Entity Targeted:** Individuals and organized criminal groups operating unregistered crypto exchanges, engaging in investment fraud schemes involving crypto, or using crypto for money laundering.

**Violation Type:** Illegal entrepreneurial activity (operating a crypto exchange without HTP registration), fraud, money laundering, theft of crypto assets.

**Penalty Amount:** Varies greatly. These are criminal cases, leading to arrests, investigations, and potential imprisonment, confiscation of assets, and restitution orders. The "penalty amount" is not a fixed fine but relates to the scale of the illicit activity (e.g., millions of dollars laundered or stolen) and subsequent asset seizures.

**Date:** **Ongoing trend throughout 2021-2024.** Numerous reports describe such operations being uncovered. It's difficult to pinpoint a single "most significant" one, as they often follow a similar pattern. Examples often involve sums ranging from hundreds of thousands to several million USD equivalent in crypto.

**Outcome:** Arrests, initiation of criminal proceedings, asset seizures (including crypto and traditional assets), and potential convictions with prison sentences.

**Source URLs (Examples of such reports):**

MVD report on arresting a group for operating an illegal crypto exchange and laundering millions (June 2023, in Russian)

Investigative Committee report on a large-scale crypto fraud investigation (October 2022, in Russian)

FMD report on preventing cryptocurrency-related crimes (May 2023, in Russian)

BelTA (state news agency) report on crypto fraud arrests (July 2022, in Russian)

The HTP Administration taking regulatory action by revoking the residency of non-compliant crypto companies (e.g., WhiteBird). This is the most direct regulatory "fine" equivalent for licensed entities, as it removes their legal right to operate.

Law enforcement agencies (MVD, Investigative Committee, FMD) aggressively pursuing criminal cases against individuals and groups involved in unregistered crypto operations, fraud, and money laundering. These cases typically result in arrests, asset seizures, and criminal charges rather than administrative fines.

**Token (cryptocurrency):** A record in a distributed ledger technology (blockchain) or other information system that meets the characteristics defined by HTP regulatory acts.

Belarus regulates crypto banks as distinct licensed operators conducting specific token-related transactions using multiple currencies, rather than a generic software-hardware complex for all token activities.

**Crypto-exchange operator:** An HTP resident legal entity that carries out activities for the exchange of tokens for other tokens, fiat money, or electronic money through a crypto-exchange.

**Other activities related to tokens:** Activities such as creating and placing tokens, operating other platforms using tokens, providing services for storing tokens, and other activities determined by the HTP Supervisory Board.

**Becoming a resident of the Hi-Tech Park (HTP):** This is the fundamental prerequisite. HTP residents benefit from special tax regimes and legal frameworks.

**Obtaining specific permissions from the HTP administration:** Once an HTP resident, an entity intending to engage in virtual asset activities must apply for and receive permission from the HTP administration to perform specific types of token-related activities (e.g., operating a crypto-exchange, providing custody services).

Exchanges (Crypto-exchange operators) in Belarus are now regulated under a framework that authorizes 'cryptobanks,' which combine token services with traditional banking operations, as of January 16.

**Specific Permission:** To act as a "crypto-exchange operator" or "operator of a token exchange platform." This involves exchanging tokens for fiat money, electronic money, or other tokens.

**Custody Providers (Virtual Asset Service Providers - VASPs offering custody):**

**Specific Permission:** Activities related to "other platforms using tokens" or "providing services for storing tokens." This covers the secure storage and management of virtual assets on behalf of clients.

**Payment Processors (handling virtual assets):**

**Specific Permission:** If the payment processor directly handles virtual assets (e.g., converting crypto to fiat for merchants, facilitating crypto payments), it would likely fall under "operator of a crypto-exchange" or "operator of other platforms using tokens" or "other activities related to tokens" requiring specific HTP permission.

**Statutory Fund:** While there isn't a specific statutory fund requirement for *crypto activities themselves*, a company must establish a Belarusian legal entity and meet the minimum statutory fund requirements for legal entities in Belarus (currently a very low amount for LLCs, but may be higher for JSCs).

**Security Deposit:** For HTP residents acting as **crypto-exchange operators or token exchange operators**, a special security deposit is required. This deposit must be maintained in a separate bank account in Belarus and is currently **USD 500,000 (or equivalent in EUR)**. This deposit serves as a guarantee for clients' funds and assets.

**AML/KYC (Anti-Money Laundering / Know Your Customer):**

HTP residents engaging in virtual asset activities are subject to **strict AML/CFT (Combating the Financing of Terrorism) requirements** in line with international standards, particularly those of the Financial Action Task Force (FATF).

Decree No. 8 specifically mandates compliance with AML/CFT legislation. This includes:

Implementing robust KYC procedures for all clients (identification, verification).

Monitoring transactions for suspicious activities.

Reporting suspicious transactions to the relevant financial intelligence unit (FIU) – the Department of Financial Monitoring of the State Control Committee of Belarus.

Maintaining detailed records of all transactions and client data.

Appointing an AML/CFT compliance officer.

Implementing internal control programs and training staff.

A **Belarusian legal entity** must be established and registered as an HTP resident. This implies a physical presence, office space, and local management in Belarus.

The HTP administration will oversee compliance and operations.

Belarus has a data protection law established in 2021 and is currently implementing new government measures to strengthen national cybersecurity (as of 2026), but the claim's assertion of 'robust IT infrastructure, cybersecurity measures, data protection protocols, and internal control systems' is outdated and does not reflect the evolving legal and regulatory landscape.

**Audit:** Annual audits by independent auditors are required.

**Qualified Personnel:** Experienced and qualified management and staff, particularly for compliance, IT security, and financial operations.

**Business Plan:** A detailed business plan outlining the intended activities, operational model, risk management strategies, and financial projections is necessary for HTP admission.

**Establish a Belarusian Legal Entity:** Form a legal entity (e.g., LLC) in Belarus.

Belarusian entities must prepare application documents, but specific requirements are being updated to align with new international (Antarctic Treaty consultative status) and domestic (AI standards in 2026) regulatory frameworks.

Business plan detailing the proposed activities, including the use of blockchain technology and virtual assets.

Copies of statutory documents of the legal entity.

Information about the company's management and founders.

**Submit Application to HTP Administration:** The application and supporting documents are submitted to the HTP administration.

**Due Diligence and Review:** The HTP administration conducts a thorough review of the application, business plan, and the applicant's background. They assess the project's innovativeness, economic viability, and compliance with HTP criteria.

**Decision by HTP Supervisory Board:** The HTP Supervisory Board makes the final decision on admission.

**Registration as HTP Resident:** Upon approval, the company is registered as an HTP resident.

**Specific Application:** Once an HTP resident, the company must submit a separate application to the HTP administration specifically requesting permission to engage in virtual asset activities (e.g., crypto-exchange operations, custody services).

**Detailed Operational Plan:** This application will require an even more detailed operational plan for the specific crypto activities, including:

Technical specifications of the platform/systems.

Belarus has shifted from standard risk management policies to conducting military drills with Russian nuclear weapons, reflecting a high-risk national security posture.

Belarus has tightened internal control procedures over internet access, including restrictions on mobile data and reduced connection quality.

Proof of the security deposit for crypto-exchange/token exchange operators.

**Review and Approval:** The HTP administration reviews these detailed plans for compliance with Decree No. 8 and related HTP internal regulations. They may conduct further checks or request additional information.

**Granting of Permission:** Upon successful review, the HTP administration grants permission for the specific virtual asset activities.

This is the primary legal act. Finding an official English translation can be challenging. You often find summaries or unofficial translations by legal firms. The original Russian text is available on the National Legal Internet Portal of Belarus.

**National Legal Internet Portal of Belarus (Russian original):** https://pravo.by/document/?guid=12551&p0=Pd1800008&p1=1&p5=0

*Note: For an English understanding, it's often necessary to consult legal firms specializing in Belarusian law, as official translations may not be readily available or up-to-date on government sites.*

**Hi-Tech Park (HTP) Official Website:**

This website provides general information about the HTP, its residents, and the application process, though specific detailed regulations for crypto activities might be found through direct consultation or within the HTP resident's internal documentation.

**Note:** If a payment processor only handles fiat currency payments for businesses involved in crypto (but doesn't touch crypto itself), they would generally be subject to standard Belarusian banking/payment services regulations, not necessarily HTP Decree No. 8. However, given the HTP's nature, many such services would be part of an HTP resident's overall offering.

**Decree of the President of the Republic of Belarus No. 8 "On the Development of the Digital Economy" dated December 21, 2017 (as amended)**: This foundational decree legalizes and regulates activities involving digital tokens (cryptocurrencies) for Hi-Tech Park residents, including exchanges, initial coin offerings (ICOs), and other related services. It explicitly mandates that HTP residents engaged in these activities must comply with AML/CFT legislation.

**Law of the Republic of Belarus No. 165-Z "On Measures for Preventing the Legalization of Proceeds from Crime, Financing of Terrorist Activities and Financing the Proliferation of Weapons of Mass Destruction" dated June 30, 2014 (as amended)**: This is the overarching national AML/CFT law that applies to all financial institutions and designated non-financial businesses and professions (DNFBPs) in Belarus, including those operating under Decree No. 8 when conducting financial operations involving virtual assets. It outlines the general principles and specific obligations for AML/CFT compliance.

**Regulations and Rules issued by the Hi-Tech Park Administration**: The HTP Administration, as the direct regulator of crypto activities, issues specific rules and instructions that elaborate on the AML/CFT requirements for its residents, ensuring compliance with both Decree No. 8 and the general AML law. These typically align with FATF recommendations.

**Identification and Verification of Customers:**

**For Individuals:** Obtaining and verifying name, date of birth, place of residence, citizenship, passport details (series, number, date of issue, issuing authority), and sometimes tax ID number. Verification must be based on reliable, independent source documents or data.

**For Legal Entities:** Obtaining and verifying legal name, registration number, legal form, address of incorporation, proof of existence, details of directors/managers, and beneficial ownership information.

**Identification of Beneficial Owners:** VASP must identify and verify the identity of the beneficial owner(s) of the customer, regardless of the ownership structure. For legal entities, this means identifying individuals who ultimately own or control more than a certain percentage (e.g., 25%) of the entity, or who otherwise exercise control.

**Purpose and Intended Nature of Business Relationship:** Understanding the customer's business activities, the purpose of their transactions, and the intended nature of the ongoing relationship.

**Ongoing Monitoring:** Continuously monitoring the business relationship and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile. This includes scrutinizing transactions for unusual patterns.

**Risk-Based Approach:** VASPs must implement a risk-based approach to CDD. This means:

**Simplified Due Diligence (SDD):** May be applied in specific low-risk scenarios.

**Enhanced Due Diligence (EDD):** Must be applied to higher-risk situations, such as transactions involving Politically Exposed Persons (PEPs), customers from high-risk jurisdictions (as identified by FATF or national authorities), complex or unusually large transactions, or situations where there are suspicions of money laundering/terrorism financing. EDD involves obtaining additional information, conducting more rigorous verification, and requiring higher-level management approval.

**Source of Funds/Wealth:** For high-risk clients or transactions, VASPs are expected to take reasonable measures to establish the source of funds or source of wealth.

**Reporting Obligation:** Any transaction or attempted transaction that the VASP suspects to be related to money laundering, financing of terrorism, or financing the proliferation of weapons of mass destruction, regardless of the amount, must be reported.

**Reporting Authority:** The reports are submitted to the **Financial Monitoring Department of the State Control Committee of the Republic of Belarus**.

**Timing:** Reports must be made without delay, typically within 24-48 hours of forming a suspicion.

**No Tipping-Off:** VASPs and their employees are prohibited from informing the customer or any third party that a suspicious transaction report has been or will be made.

**Customer Identification Records:** All documents and information obtained during the CDD process, including identity documents, beneficial ownership information, and risk assessments.

**Transaction Records:** Details of all virtual asset transactions, including dates, types of assets, amounts, parties involved (senders and recipients), wallet addresses, and any relevant messages or references.

**Business Correspondence:** Records of communications related to customer due diligence and transactions.

**Suspicious Transaction Reports:** Copies of all STRs submitted, along with supporting documentation and internal decision-making processes.

**Role:** The HTP Administration is the primary direct regulator for companies operating within its jurisdiction, including those involved in virtual asset activities. It grants residency status, sets specific rules and requirements for crypto operations under Decree No. 8, and oversees their adherence to these rules, which encompass AML/CFT obligations. The HTP conducts audits and inspections of its residents.

**Website:** https://www.park.by/ (available in English)

**Financial Monitoring Department of the State Control Committee of the Republic of Belarus (FIU)**:

**Role:** This department functions as the national Financial Intelligence Unit (FIU). It is responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial intelligence to law enforcement agencies. It also plays a role in developing national AML/CFT policy and coordinating with international bodies. While HTP administers specific crypto rules, the FMD receives all STRs.

**Website:** The Financial Monitoring Department is part of the State Control Committee.

State Control Committee: https://www.kgk.gov.by/ (The FMD's specific section might be under "Structure" or "Departments" on this site).

**Executive Order (E.O.) 14038 "Blocking Property of Certain Persons Contributing to the Situation in Belarus" (August 9, 2021):** Expands the scope of the national emergency declared in E.O. 13405, authorizing blocking of property and interests in property of individuals and entities involved in undermining democratic processes, human rights abuses, and corruption in Belarus.

**E.O. 14065 "Blocking Property of Certain Persons Contributing to the Situation in Ukraine" (February 24, 2022) and subsequent actions:** While primarily aimed at Russia, Belarus's involvement in facilitating the invasion has led to parallel designations and prohibitions, particularly concerning its financial sector and state enterprises.

**Specially Designated Nationals and Blocked Persons (SDN) List:** OFAC designates numerous Belarusian individuals (including President Lukashenka, his family members, and high-ranking officials) and entities (state-owned enterprises, banks, defense companies) to the SDN List. U.S. persons are generally prohibited from transacting with SDNs, and their property and interests in property subject to U.S. jurisdiction are blocked.

**Sectoral Sanctions Identifications (SSI) List:** Though less prevalent for Belarus than for Russia, certain entities may be subject to more limited restrictions, e.g., on debt or equity.

**OFAC Compliance Framework:** VASPs must implement robust, risk-based compliance programs that include:

**Management Commitment:** Clear support for compliance.

**Risk Assessment:** Identifying inherent and residual sanctions risks.

**Internal Controls:** Policies and procedures to mitigate identified risks (e.g., KYC/CDD, transaction screening, geographic restrictions).

**Testing and Auditing:** Regular review of the program's effectiveness.

**Training:** Ensuring staff understand their responsibilities.

**Virtual Currency Guidance:** OFAC has issued specific guidance clarifying that sanctions obligations apply to all participants in the virtual currency ecosystem. VASPs are expected to implement tools and processes to identify, prevent, and report sanctioned transactions. This includes screening wallet addresses, IP addresses, and transaction metadata.

OFAC Sanctions Compliance Guidance for the Virtual Currency Industry

**Geographic Restrictions:** Prohibitions extend to transacting with sanctioned entities/individuals located in or ordinarily resident in Belarus, or otherwise linked to the Belarusian regime as per specific designations.

Council Regulation (EC) No 765/2006, as extensively amended, still serves as the core EU sanctions framework on Belarus but now goes well beyond initial asset freezes and travel bans, encompassing a wide range of sectoral and economic restrictive measures in addition to listings of individuals and entities.

Council Regulation (EU) 2022/355 (March 2, 2022, and subsequent amendments): This regulation significantly broadened the scope of sanctions in response to Belarus's involvement in the Ukraine war.

**Specific Inclusion of Crypto-Assets:** The EU explicitly extended the definition of "transferable securities" and "money-market instruments" to include crypto-assets, effectively bringing them under the scope of existing financial restrictions (asset freezes, prohibitions on making funds available). It also prohibited the provision of crypto-asset wallet, account, or custody services to Belarusian persons or entities, with limited exceptions.

Council Regulation (EU) 2022/355 and its amendments have been superseded by more recent EU sanctions, including the 20th sanctions package (April 2026) which amended Council Regulation (EU) No 765/2006 concerning Belarus, and the broader sanctions framework continues to evolve beyond these specific regulations.

The scope of EU sanctions on Belarus was expanded in December 2025 to include measures targeting hybrid activities that undermine democracy and the rule of law, as per Council Regulation (CFSP) 2025/2601 amending Regulation (EC) No 765/2006.

Asset freezes on listed individuals and entities.

Prohibition on making funds and economic resources (including virtual assets) available to listed persons.

Restrictions on access to EU capital markets.

Trade restrictions on certain goods (e.g., dual-use goods, industrial goods, timber, potash, energy products).

Restrictions on financial flows to/from Belarusian entities.

**EU Consolidated List:** The EU maintains a consolidated list of persons, groups, and entities subject to EU financial sanctions, which includes numerous Belarusian officials, military personnel, state-owned enterprises, and entities involved in sanctions evasion or support for the regime.

EU Sanctions Map (for overview)

EU Restrictive measures concerning Belarus (Contains links to the latest consolidated list)

**Know Your Customer (KYC) / Customer Due Diligence (CDD):** Robust procedures to identify and verify customers, including beneficial owners.

**Transaction Monitoring:** Systems to detect suspicious transactions, particularly those involving high-risk jurisdictions or known sanctioned entities/individuals.

Screening all customers and transaction counterparties against the EU Consolidated List (including the expanded scope for hybrid activities) and other relevant national lists.

**Geographic Restrictions:** Prohibitions on transacting with or providing services to sanctioned Belarusian entities or individuals, as well as general prohibitions on circumvention.

**Relevance for VASPs:** While there isn't a "UN Sanctions List for Belarus" that directly impacts crypto, VASPs must comply with the UN Consolidated Sanctions List as a baseline. Any individual or entity designated by the UNSC, regardless of their nationality or location, is subject to asset freezes and other restrictions by all UN member states.

UN Security Council Sanctions Committees

**Comprehensive Screening:** VASPs must screen all their customers (individuals, entities, beneficial owners) and, where technically feasible, their transaction counterparties against:

Any relevant national sanctions lists of the jurisdictions in which the VASP operates or has customers.

**Perpetual/Ongoing Screening:** Screening should not be a one-time event but an ongoing process, as sanctions lists are updated frequently.

**Technology Solutions:** Utilizing blockchain analytics tools and sanctions screening software that can identify connections to sanctioned addresses, entities, and individuals is critical. This includes identifying direct and indirect exposure.

**Prohibited Engagement:** Generally, VASPs and individuals subject to OFAC or EU jurisdiction are prohibited from engaging in any transactions or activities that directly or indirectly involve sanctioned Belarusian individuals, entities, or sectors.

**Circumvention:** Any attempt to circumvent these sanctions, including through the use of virtual assets, is also prohibited and subject to severe penalties. This includes facilitating transactions for sanctioned parties, even if they are located outside Belarus, or structuring transactions to obscure the involvement of a sanctioned person.

**Restricted Services:** For example, the EU explicitly restricts the provision of crypto-asset wallet, account, or custody services to Belarusian persons or entities, with limited exceptions.

**Civil Penalties:** Can reach millions of dollars per violation, often determined on a strict liability basis (i.e., intent is not required for a violation to occur).

**Criminal Penalties:** For willful violations, individuals can face fines of up to $1 million and imprisonment for up to 20 years. Corporations can face fines in the millions.

**Reputational Damage:** Significant and lasting damage to a company's reputation and its ability to operate globally.

**Member State Dependent:** Penalties are determined by individual EU member states but are required to be "effective, proportionate and dissuasive."

**Typical Penalties:** Can include significant fines (often in the hundreds of thousands or millions of Euros) and imprisonment for serious criminal offenses.

**Loss of License:** For VASPs, non-compliance can lead to the revocation of their operating licenses.

Belarus Decree No. 8 has been superseded or amended by subsequent decrees, including Decree No. 19 (January 2025) on cryptobanks, and is no longer the sole or current digital asset legislation.

**High-Tech Park (HTP) Administration:** This is the primary body responsible for overseeing and regulating crypto activities within its special legal regime. Companies wishing to engage in crypto activities must become residents of the HTP and adhere to its specific rules and regulations.

**National Bank of the Republic of Belarus (NBB):** While the HTP framework handles most crypto-specific regulations, the NBB maintains general oversight over financial stability, payment systems, and issues related to fiat currency. It monitors risks associated with virtual assets, particularly concerning their interaction with the traditional banking system and potential for money laundering.

**Financial Monitoring Department of the State Control Committee (FMD SCC):** This body is responsible for preventing money laundering and financing of terrorism (AML/CFT). Crypto operators, as financial institutions, are subject to AML/CFT requirements supervised by the FMD SCC.

**Website:** https://www.kgk.gov.by/en/ (English page of the State Control Committee)

**Decree No. 8 "On the Development of the Digital Economy" (dated December 21, 2017, effective March 28, 2018):**

This landmark decree legalized cryptocurrencies, tokens, ICOs (Initial Coin Offerings), smart contracts, and mining operations within the HTP framework.

It granted residents of the HTP significant tax benefits (exemptions from corporate tax, VAT, and individual income tax on crypto-related income until January 1, 2023, though discussions on extension or modification occur).

It established a legal basis for "crypto-platforms" (exchanges) and "operators of token services" (custody, issuance, etc.).

It defines various types of tokens (utility, security, payment) and sets rules for their circulation.

**Reference (HTP overview):** https://www.park.by/development/digital-economy/ (This page on the HTP website discusses the decree and its implications, though a direct PDF of the decree in English is often found via legal resources rather than direct government links).

**Decree No. 222 (dated June 28, 2021):**

As of September 2025, President Lukashenko urged regulators to finalize clear crypto rules, indicating that earlier decree amendments have not yet achieved settled, transparent regulation; the regulatory environment is still evolving.

**Legally Permitted and Regulated:** Crypto trading, exchanges, and other related services (such as ICOs, token issuance, and custody) are legally permitted and regulated in Belarus. However, these activities *must be conducted by residents of the High-Tech Park*.

In Belarus, entities can operate crypto services either as HTP residents or through newly licensed crypto banks, which allow handling 11 types of transactions in 26 currencies, potentially offering an alternative to HTP residency.

**Tax Benefits:** HTP residents involved in crypto activities historically benefited from significant tax incentives, making Belarus an attractive jurisdiction.

OFAC's General License 14 issued in March 2026 authorizes certain transactions under the Belarus Sanctions Regulations, indicating that while the legal framework is clear, recent regulatory action has reduced some implementation hurdles.

**Banking Difficulties:** Belarusian crypto exchanges and operators struggle to obtain and maintain correspondent banking relationships with international banks. Many global financial institutions are de-risking and avoiding transactions with Belarusian entities due to the extensive international sanctions imposed on Belarus following political events and its involvement in the conflict in Ukraine.

Belarus has legalized crypto banks, enabling conversion between fiat currency and cryptocurrency through traditional banking channels, which improves accessibility for users.

**Reduced International Participation:** The practical difficulties have significantly hampered Belarus's ambition to become a global hub for digital assets, despite its progressive legal framework.