Uzbekistan is one of the few jurisdictions in the region where crypto-asset circulation is neither banned nor ignored, but built into the legal framework: a special regulatory regime is in force, a dedicated state body operates, and licences and permits are issued. For business this means a clear fork in the road: a project either operates within the legal framework — with a licence, policies and reporting — or accumulates risk for itself and its counterparties. This article covers how the regulation works and what legal support for a crypto project looks like in practice.
The regulator: National Agency of Perspective Projects
The authorised body for crypto-asset circulation is the National Agency of Perspective Projects of the Republic of Uzbekistan (NAPP), established by Presidential Decree No. UP-121 of 27 April 2022 through the transformation of the National Agency of Project Management. NAPP is responsible for the state policy in the field of crypto-asset circulation, protection of investors’ rights and legitimate interests, participation in anti-money-laundering and counter-terrorism-financing measures, and promotion of projects based on distributed ledger technology. NAPP is the licensing and permitting authority for the sector, and a specialised laboratory for testing and studying innovative technologies in crypto-asset circulation operates within its structure.
Where a lawful launch starts
The first question for any project is legal classification: what exactly the company will do in the terms of Uzbek regulation, and which permit or licence that activity requires. The answer determines the requirements for corporate structure, capital, internal policies and reporting. The second question is the form of presence: foreign teams choose between incorporating a local entity and structuring through other jurisdictions around an Uzbek licence. The third is the regulator’s file: constitutional documents, the business model, a product description, internal policies and procedures.
Mistakes at this stage are the most expensive: a wrong classification leads to refusal, and launching “ahead of the licence” leads to blocked settlements and claims that later have to be untangled in disputes.
Token listing: what platforms request
Token issuance and listing is a separate layer of work. Trading platforms and counterparties request a legal opinion from the issuer: how the token is classified, whether it amounts to an instrument requiring separate regulation, who issued it and on what basis, and what rights it carries. The opinion comes with a document package — corporate resolutions on the issuance, a tokenomics description, AML and KYC policies, terms of use and a public offer.
We prepare such opinions and the supporting documentation to the requirements of the specific platform — one of the most frequent requests web3 projects bring to us.
Life after launch
A licence is not the finish line but the start of recurring obligations: keeping internal policies current, identifying customers, communicating with the regulator, handling cross-border payments correctly under currency control rules, and protecting users’ personal data. Add sector-specific contracts — from liquidity provision agreements to infrastructure provider arrangements — and it becomes clear why a crypto project needs a standing legal function rather than a one-off consultation.
Black Swan Consulting supports blockchain and crypto projects in Uzbekistan: structuring, NAPP licences and permits, listing opinions, compliance policies, contracts and disputes. Read more on the Blockchain & Cryptocurrency industry page.