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Legal framework for crypto banking in Belarus links tokens to finance today

by ICN.live
January 16, 2026

Adnan Al-Jaziri

Key Points

The decree integrates all token activity with traditional payments, monitored by the government.
All crypto service providers are required to be incorporated as a joint stock company and have their headquarters at the Belarus Hi-Tech Park, which means they are subject to the same regulations and reporting requirements as traditional banks.
Providers can offer wallets, account management, and settlement services, and they will be able to do so under one compliance regime.
To operate, crypto service providers must be registered with the National Bank of Belarus (NBB) prior to launching token-based products and services.
Registration with the NBB will allow them to operate within an anti-money laundering (AML) framework and ensure compliance with existing reporting requirements.

Legal framework for crypto banking in Belarus aligns token activity with regulated finance and payments channels.

As part of registration, crypto service providers must provide details regarding the composition of their board of directors, their technology risk management practices, and their security controls.

All providers must also comply with the requirements of the Hi-Tech Park’s supervisory board. The supervisory board will oversee the provider’s compliance with all applicable laws, as well as its technical practices and procedures.

In addition, all providers must demonstrate appropriate leadership, adequate controls over their IT environment, and disclose the identities of all individuals who own more than 10% of their shares.

All providers must also segregate their customers’ assets from their own corporate assets in order to protect customer assets in the event of bankruptcy or other insolvency.

The decree will also establish a formal complaints process, and it will require all providers to inform their customers if there are any disruptions to service, and to provide clear instructions on how customers can terminate their relationship with the provider.

Dual Oversight Link Finance Controls with Technology Governance

According to officials, the dual-oversight approach was taken to enable the use of tokens for payment purposes, while minimizing the potential for a fragmented approach to compliance among multiple stakeholders. The use of token-based payments will now be allowed to occur within a unified compliance standard, allowing both banks and non-bank financial institutions to provide wallet services, issue tokens, and make payments under a single regulatory umbrella.

I believe the most significant change is that we are shifting from an experimental phase to a production phase in terms of governance. The State has provided a number of pathways for development, while requiring that all parties engaged in providing services report clearly on their respective data, reporting, and enforcement obligations.

However, the State has limited market entry to those providers who are prepared to meet very high verification requirements and ongoing audit requirements. As a long-standing policy position, the State prefers permitted activities to occur within established channels rather than occurring outside of them.

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A Domestic Alternative

Additionally, the State has discouraged the operation of grey markets, including offshore platforms targeting residents of Belarus without local authorization. The current regulatory model provides a domestic alternative to such offshore platforms; however, it is only available through registered entities that agree to be overseen by the State.

When promoting the adoption of cryptocurrencies by banks, officials cited economic pressures and cross-border settlement needs. In particular, they noted that tokens were becoming increasingly important in international payments and remittances, and therefore, they would support the use of tokens in such transactions. The State will, therefore, direct experimentation into licensed entities and away from informal venues without audited risk controls. Belarus views itself as a supporter of business while maintaining consumer protection and enforcement capabilities.

Token service menu items may include token creation, custody, exchange, and payment processing via a regulated entity. Providers will utilize identity verification, transaction screening, and suspicious activity reporting, etc., utilizing compliance systems familiar to providers and their customers.

Customers will experience familiar interfaces and documentation, such as those utilized in fiat services today, to reduce confusion associated with the entry of new users into token markets.

Legal Framework for Crypto Banking in Belarus: Shaping Controlled Growth Pathway

Providers will continue to be expected to demonstrate capital adequacy, cybersecurity, and operational continuity during the approval process. The providers’ technology risk management teams must create documentation evidencing testing, incident response plans, and vendor management of critical systems.

Governance requirements will force Boards of Directors to evaluate product risks, changes to models, and reliance upon third-party dependencies, to mitigate the potential for outages, data breaches, and uncontrolled exposures to token and payment operations.

Officials also indicate that there will be a graduated approach to product availability, transitioning pilot programs to broader availability once reviewed. Providers will be expected to evidence measured adoption, clearly articulate customer obligations, and charge customers a reasonable price commensurate with the delivered service. The regulators can suspend or limit specific features of a product if warning signs arise from regular monitoring activities. Industry builders view this signal as an opportunity to build within a predictable regulatory perimeter, with stable expectations. The model emphasizes the regulation of digital assets in Belarus that coordinates with the existing finance infrastructure and laws.

Companies that are willing to operate domestically will be viewed favorably by partners, payment rails, and institutional customers. These preferences will align with banks that seek to utilize compliant token services, and not speculative exposure without clear accountability.

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International observers will be watching the volume of transactions, fees charged, and the variety of products offered during the first year. Successful implementation will depend upon the provision of clear implementation guidelines, sufficient processing capability, and cooperation amongst banks and technology vendors. If successful, banks may begin to offer cross-border payments utilizing approved token rails. Success may also prompt nearby jurisdictions to adopt similar dual oversight structures for the purpose of adoption.

However, the decree does not address questions surrounding tax treatment and foreign participation requirements. The regulators will likely issue additional guidance as the providers work their way through the formal review and testing phases. Education of the marketplace will be key as customers need to understand plain language regarding their rights, risks, and incident handling. Plain language disclosure will help to align customers’ expectations with the reality of the service being offered, whether it relates to custody, transfer, or settlement finality.

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What does Decree No. 19 change for crypto banking providers in Belarus?

Decree No. 19 creates a single path for token services inside licensed entities. Providers must become joint stock companies, enter a central bank register, and secure Belarus Hi Tech Park residency. These steps align token activity with bank grade compliance, covering identity checks, screening, reporting, and asset segregation. The decree also binds firms to the Park’s supervisory board decisions, which address technology risk and governance practices. Together, the two bodies coordinate finance and technology oversight, reinforcing accountability across operations. Customers should see clearer disclosures, stronger continuity planning, and better complaint handling. Institutions gain predictable requirements for building custody, exchange, and token-based payments. The result is an integrated model that reduces gray market reliance and focuses activity within enforceable, domestic rules.

How will customers experience services under the new framework?

Customers will onboard through recognized entities with standard documentation, identity checks, and support processes. Wallets, custody, exchange, and payments will operate behind familiar interfaces, paired with clear service terms. Firms must segregate customer assets from corporate funds and publish procedures for service disruptions and exits. Dispute mechanisms and regulatory contacts will be visible, improving confidence when problems arise. Transaction monitoring and reporting will run through existing compliance pipelines, helping detect suspicious behavior faster. Education materials should describe token risks, transfer finality, and security responsibilities in plain language. This combination of transparency and accountability aims to reduce confusion and protect new users. People gain avenues for redress while accessing token-based payments linked with established payment rails.

Why require Belarus Hi Tech Park residency for cryptobank operators?

Residency anchors technology oversight alongside financial supervision, closing gaps between product design and compliance outcomes. The Park’s supervisory board can mandate security controls, testing regimes, and incident response planning across providers. These requirements frame how firms manage vulnerabilities, vendor relationships, and data protection obligations. By tying approvals to residency, authorities keep technical standards aligned with evolving risk assessments. Residency also promotes local accountability, since management and infrastructure remain visible to domestic regulators. Companies that accept this commitment gain easier integration with partners and institutional clients. The approach favors prepared firms, which already maintain documented controls and audit ready processes. Customers benefit because technology reviews sit next to financial risk oversight, producing consistent expectations across services.

Does the model restrict innovation or open new opportunities for banks and startups?

The model opens opportunities for organizations prepared to meet strict governance and compliance requirements. Banks can extend payment offerings using tokens, while startups contribute specialized technology under shared standards. Innovation happens inside registered entities, which must publish disclosures, maintain audits, and protect customers. This structure limits gray market services that bypass obligations and elevate unmanaged risk. Firms that demonstrate resilient systems, fair pricing, and clear value propositions should progress from pilots to broader availability. Cross border settlement features could expand when partners accept the credibility of regulated token rails. Over time, competitive pressure and supervision may improve reliability, reduce outages, and streamline onboarding. The framework balances product growth with enforceable accountability, inviting investment while maintaining strong consumer protections.

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