Self-custodial wallet / non-custodial software in 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.

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.

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

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.

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.

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