NAPP Licensing · Uzbekistan · Digital Asset Law
Crypto & NAPP Licensing
in Uzbekistan
Uzbekistan is one of the few countries in the world with a clear, functional regulatory framework for crypto exchanges, wallets, and mining. KADIR LAW prepares and submits the full NAPP license application — so you operate legally from day one.
2018
Legal Since
4
License Types Available
2–4
Months to License
Why Uzbekistan?
A Rare Thing: A Clear Crypto Legal Framework
Most jurisdictions either ban crypto outright or leave operators in a permanent grey zone. Uzbekistan took a different path. Since 2018, Presidential Decree PP-3316 and a series of subsequent regulations have created one of the clearest licensing frameworks for digital assets in the post-Soviet region.
The National Agency for Perspective Projects (NAPP) is the single regulator for all crypto activity. Licenses are available for exchanges, custodial wallets, token issuance platforms, and mining operations. Foreign-owned companies can obtain licenses. There is no ambiguity about whether crypto is legal — it is, if you are licensed.
This clarity is a competitive advantage. Operators who obtain NAPP licenses now are establishing regulated positions in a market of 35+ million people that has not yet been saturated by licensed competitors.
Legal Since
2018
Regulator
NAPP
Foreign Ownership
100%
Timeline
2–4 months
What We License
Four Types of NAPP Crypto Licenses
Crypto Exchange License
NAPP Exchange Registration
For platforms enabling users to buy, sell, or swap cryptocurrencies. Covers spot trading, OTC desks, and crypto-to-fiat conversion services. This is the most comprehensive NAPP license and the one required to operate a publicly accessible crypto trading platform in Uzbekistan.
Key Requirements
- Registered Uzbek legal entity (100% foreign-owned permitted)
- Certified AML/KYC policy and compliance officer
- Capital adequacy confirmation
- Technical infrastructure documentation
- Beneficial ownership disclosure (UBO)
Custodial Wallet License
Digital Asset Custody
For companies holding private keys and managing crypto assets on behalf of clients — including wallets embedded in fintech apps, exchange custody functions, and standalone digital asset storage services. Required whenever your business controls user funds or private keys.
Key Requirements
- Cold/hot wallet security policy
- User asset segregation documentation
- AML/KYC program certified by compliance officer
- Cybersecurity audit or penetration test report
- Insurance or capital reserve confirmation
Crypto Mining License
Industrial Mining Registration
For commercial mining operations operating ASICs, GPU farms, or data centres for proof-of-work cryptocurrency mining. Uzbekistan offers designated mining zones including BesQala Mining Valley (PP-143) with preferential energy tariffs. Individual mining does not require a license; commercial-scale operations do.
Key Requirements
- NAPP registration as mining entity
- Industrial energy-tariff agreement
- Equipment customs clearance documentation
- Operating location confirmation
- Periodic production and hash-rate reporting
Token Issuance License
STO / Digital Token Offerings
For companies planning to issue digital tokens — whether utility tokens, security token offerings (STOs), or other digital asset instruments. Uzbekistan permits regulated token issuance under NAPP oversight, with prospectus-equivalent disclosure requirements and investor protection provisions.
Key Requirements
- Token whitepaper and legal characterisation
- Smart contract audit (third-party)
- Investor disclosure documentation
- AML/KYC for token purchasers
- Use-of-proceeds documentation
Our Process
How KADIR LAW Handles
Your NAPP Application
Week 1
Business Model Assessment & License Selection
We review your product, user flows, and revenue model to confirm which NAPP license type applies — or whether multiple licenses are required. We also identify any structural adjustments needed before application, such as beneficial ownership simplification or compliance officer appointment.
Weeks 2–4
AML/KYC Policy & Compliance Documentation
The most common reason NAPP applications are rejected or delayed is an inadequate AML/KYC program. We draft a full compliance policy tailored to your business type — including customer due diligence procedures, transaction monitoring rules, suspicious activity reporting protocols, and sanctions screening. We also prepare the beneficial ownership register and UBO declarations.
Weeks 3–5
Entity Registration & Corporate Package
If you do not yet have a registered Uzbek company, we handle full incorporation in parallel with compliance documentation — charter, founder resolutions, statutory documents, and tax registration. If you have an existing entity, we review its documents and make any adjustments required for the NAPP application.
Week 5–6
NAPP Application Submission & Follow-up
We submit the complete package to NAPP and act as your authorised representative throughout the review. We handle all regulator follow-up requests, respond to queries, and supply supplementary information as needed — without delays caused by translation or miscommunication.
Month 2–4
License Approval & Ongoing Compliance Support
Upon NAPP approval, we provide a compliance calendar covering all periodic reporting and renewal obligations. We remain available for regulatory updates — Uzbekistan's crypto framework continues to evolve, and we monitor all NAPP and Central Bank publications to keep your operations fully compliant.
Case Study
OTC Crypto Exchange — Cyprus & Georgia
Existing EU-registered entity · Expanding to Central Asia
An OTC crypto desk registered in Cyprus approached KADIR LAW in mid-2025. Their existing AML/KYC policy was written to EU AMLD standards, which did not map cleanly onto NAPP's specific disclosure requirements. Their initial attempt to file without legal counsel had been rejected at the document review stage.
We conducted a gap analysis between their existing compliance documentation and NAPP's requirements, rewrote the AML/KYC policy to meet the Uzbek regulatory standard while preserving compatibility with their EU obligations, and restructured their beneficial ownership documentation to reflect the correct legal hierarchy.
The resubmitted application passed NAPP's initial review without a single follow-up query. The exchange license was issued 58 working days after resubmission. The client is now operating the first licensed OTC desk in Uzbekistan under their brand.
58
Working Days to License
0
NAPP Follow-up Queries
1st
Licensed OTC Desk in UZ
FAQ
Common Questions About
NAPP Crypto Licensing
Ready to Apply?
Get Your NAPP License
With Zero Rejected Applications
We review your business model, confirm the correct license type, and tell you exactly what documentation you need — before you spend a single dollar on incorporation. The first consultation is free.