Stablecoin issuer / redeemer in Uzbekistan

National Agency for Perspective Projects (NAPP): The primary regulator for the circulation of virtual assets, including licensing of Virtual Asset Service Providers (VASPs).

Central Bank of the Republic of Uzbekistan (CBU): Regulates payment systems, e-money, and banks. It would be involved if a stablecoin is classified as e-money.

Capital Market Development Agency: Oversees securities markets. It would be involved if a stablecoin is classified as a security.

As Virtual Assets: Most stablecoins, especially those backed by fiat currency or other assets but not issued by regulated e-money institutions, would likely fall under the NAPP's "virtual asset" classification. This is the default for a broad range of crypto assets.

As E-money: If a stablecoin is explicitly backed 1:1 by a fiat currency, issued by an entity that obtains an e-money issuer license from the Central Bank, and functions as a stored monetary value for making payments, it could be classified as e-money under the Law "On Payments and Payment Systems." This would subject it to CBU regulation, not NAPP.

As Securities: If a stablecoin represents a claim to profits, ownership rights, or debt obligations in a way that resembles traditional financial instruments, it could be classified as a security and fall under the Capital Market Development Agency's oversight. This is less common for typical stablecoins but possible for certain asset-backed tokens.

For Virtual Assets: The NAPP framework for virtual assets (CM Resolutions No. 648 and 649) does not impose specific reserve requirements on the issuers of stablecoins classified solely as "virtual assets." The focus is on licensing VASPs and ensuring compliance with AML/CFT rules. Reserve backing would be a matter of the issuer's terms and conditions, not a regulatory mandate for this classification.

For E-money: If a stablecoin is classified as e-money, the Central Bank of Uzbekistan's regulations for e-money issuers would apply. These typically include prudential requirements such as safeguarding user funds by holding them in segregated accounts with credit institutions, often with a 1:1 backing in fiat currency or highly liquid, low-risk assets.

For Virtual Assets: Any entity acting as a Virtual Asset Service Provider (VASP), which includes activities like issuance, exchange, storage, and management of virtual assets (including stablecoins classified as such), must obtain a license from NAPP. CM Resolution No. 649 details the licensing procedures, requirements (e.g., minimum charter capital, qualified personnel, robust IT infrastructure, AML/CFT compliance).

For Securities: If a stablecoin is classified as a security, the issuer would likely need appropriate licenses from the Capital Market Development Agency.

For Virtual Assets: The NAPP framework for virtual assets (CM Resolutions No. 648 and 649) does not impose specific reserve requirements on the issuers of stablecoins classified solely as "virtual assets." The focus is on licensing VASPs and ensuring compliance with AML/CFT rules. Reserve backing would be a matter of the issuer's terms and conditions, not a regulatory mandate for this classification.

For E-money: If classified as e-money, users would have a statutory right to redeem their e-money at par for fiat currency from the issuer at any time, as per the Central Bank's regulations.

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.

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.

Clear Rules: Development of clear and transparent rules for interaction with clients, including terms of service, fee structures, and complaint resolution procedures.

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.

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.

Identification and Verification:

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:

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).

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.

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

Transactions outside of licensed platforms are generally prohibited.

It also bans anonymous transactions and the use of virtual assets for payments for goods/services within Uzbekistan.

Presidential Decree No. PP-180 of August 16, 2022: "On measures to regulate the sphere of circulation of virtual assets in the Republic of Uzbekistan."