DeFi protocol frontend in Uzbekistan

Presidential Decree No. UP-106 "On measures for further development of the digital economy in the Republic of Uzbekistan" dated March 16, 2022. This decree established NAPP as the regulator and laid out the general principles.

Resolution of the Cabinet of Ministers No. 445 "On approval of the Regulation on the procedure for licensing the activities of service providers in the field of circulation of crypto-assets" dated August 22, 2022. This is the most critical document detailing licensing and operational requirements.

Legal Entity Status: The applicant must be a legal entity registered in the Republic of Uzbekistan.

Authorized Capital: Compliance with the minimum authorized capital requirements as stipulated by NAPP (e.g., for crypto exchanges, it's often set at a significant amount in USD equivalent, which usually applies to other VASPs like custodians as well).

AML/CFT Compliance: Strict adherence to international Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) standards, including FATF recommendations. This involves:

Developing and implementing internal AML/CFT policies and procedures.

Conducting Know Your Customer (KYC) for all clients.

Monitoring transactions for suspicious activities.

Reporting suspicious transactions to NAPP and other relevant authorities.

IT Security: Implementation of robust information security systems, including:

Obtaining an information security certificate (e.g., ISO 27001).

Data Storage: All information related to virtual asset turnover and client data must be stored on servers located within the territory of the Republic of Uzbekistan.

Integration with NAPP Systems: Service providers must integrate their information systems with NAPP's unified information system for monitoring and supervision.

Qualified Personnel: Directors and key personnel must meet qualification requirements, including relevant experience and a clean criminal record.

Internal Control System: Establishment of an effective internal control system to manage operational risks.

Primary AML/CFT Law:

Presidential Decree No. PD-269 of September 2, 2022, "On Measures for the Further Development of the Regulatory Framework for the Circulation of Virtual Assets."

Cabinet of Ministers Resolution No. 592 of October 18, 2022, "On Approval of the Regulation on the Procedure for Licensing the Activities of Virtual Assets Stores and the Regulation on the Procedure for Licensing the Activities of Cryptocurrency Exchanges."

Regulation on the Procedure for Carrying Out Anti-Money Laundering and Counter-Terrorism Financing Measures for Virtual Asset Market Participants (Registered by the Ministry of Justice on August 9, 2023, No. 3456).

Identification and Verification:

Source of Funds/Wealth: For high-risk clients or transactions exceeding a certain threshold, VASPs must identify and verify the source of funds or wealth involved.

Beneficial Ownership: Identify and take reasonable measures to verify the identity of the beneficial owner(s) of the client. For legal entities, this typically means identifying individuals who own or control more than a specified percentage (e.g., 25%) of the company, or who otherwise exercise control through other means.

Ongoing Due Diligence:

Categorize clients based on their ML/TF risk (e.g., low, medium, high).

Apply Enhanced Due Diligence (EDD) for high-risk clients, transactions, or business relationships. This includes:

Politically Exposed Persons (PEPs) and their family members/close associates.

Clients from high-risk geographic areas (as identified by FATF or NAPP).

Unusual or complex transactions without an apparent economic or lawful purpose.

FATF Standards: Uzbekistan, as a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), is committed to implementing FATF standards. Future legislative changes are likely to reflect ongoing updates to FATF guidance on virtual assets, which may impact custody requirements, particularly regarding travel rule implementation and risk assessments.