Note: This is Part 2 of our comprehensive series on Armenia’s crypto framework. For an overview of the laws, market scope, and international comparisons, please read [Part 1: Complete 2026 Guide to Crypto Regulations in Armenia].
Securing a crypto license in Armenia has become a structured, supervised process under the Law on Crypto-Assets (HO-159-N), enacted as part of Armenia’s transition from regulatory grey zone to a fully regulated digital asset jurisdiction. Both new entrants and existing platforms must now meet strict licensing, capital, and ongoing compliance obligations enforced by the Central Bank of Armenia (CBA).
This guide walks founders, in-house counsel, and compliance officers through every operational requirement to obtain and maintain a CASP (Crypto-Asset Service Provider) license in Armenia in 2026, including exact capital thresholds, AML/KYC obligations, corporate tax exposure, and the binding deadlines you must meet to avoid forced cessation of operations.
Need a tailored licensing roadmap? Our Armenia-based crypto licensing team will map your business model to the correct CASP category and capital tier in one session.
CASP Licensing Requirements & Application Process
Licences are issued exclusively to legal entities registered under Armenian law as either a joint-stock company (JSC) or limited liability company (LLC) – see our guide to company formation in Armenia for the incorporation process. The exclusive business purpose of the entity must be the provision of licensed crypto-asset services. Foreign providers may operate through a licensed branch, provided it meets all local CBA requirements.
Who Can Apply for an Armenia Crypto License
| Eligible Entity | Conditions |
|---|---|
| Armenian JSC | Sole purpose: licensed crypto-asset services |
| Armenian LLC | Sole purpose: licensed crypto-asset services |
| Foreign provider (via branch) | Branch must independently meet all CBA requirements |
| Commercial banks | Must establish a separate legal entity and apply for a standalone CASP license |
Required Documentation Checklist
A complete application must include:
- Corporate Disclosure: Full details of all shareholders and ultimate beneficial owners (UBOs), alongside articles of association.
- Management Fit-and-Proper: Criminal record certificates, professional qualifications, and CVs for all directors and senior managers.
- Internal Policies: Documented risk management frameworks, AML/KYC policies, IT security protocols, and business continuity plans.
- Capital Evidence: Proof of required minimum capital held in a CBA-approved account.
Minimum Capital Requirements by Service
The CBA enforces a risk-calibrated approach to minimum capital. These thresholds represent initial and ongoing capital floors; Crypto-Asset Service Providers (CASPs) must maintain these levels throughout their operations.
(Note: Capital requirements are legally denominated in Armenian Drams (AMD). USD equivalents are approximate.)
| Service Category | Risk Level | Approx. Minimum Capital (USD) |
| Advisory Services | Lower | ~$30,000 |
| Transmission of Orders / Placement | Lower | ~$30,000–$80,000 |
| Custody and Administration | Medium | ~$130,000–$200,000 |
| Execution of Orders (on behalf of clients) | Medium | ~$130,000–$200,000 |
| Proprietary Trading | Higher | ~$400,000–$530,000 |
| Operation of a Trading Platform (Exchange) | Higher | ~$400,000–$530,000 |
AML/KYC and Market Integrity
Armenian CASPs are subject to the full suite of domestic anti-money laundering legislation, aligning with FATF standards and MONEYVAL assessments. To maintain compliance, the CBA strictly mandates that CASPs must employ at least one certified compliance specialist dedicated exclusively to AML/KYC oversight.
Customer Due Diligence (CDD) Requirements
CASPs must conduct thorough due diligence on all customers before providing services. The framework mandates a strict, risk-based three-tier approach:
| CDD Level | When Applied | Core Requirements |
| Standard CDD | All customers (default) | Identity verification (full name, date of birth, address, ID document), beneficial owner identification for corporate clients, purpose of relationship. |
| Enhanced Due Diligence (EDD) | Politically Exposed Persons (PEPs), high-risk jurisdictions, complex structures, unusual patterns. | Source of funds and wealth verification, senior management approval, enhanced ongoing monitoring, more frequent review cycles. |
| Simplified CDD | Lower-risk customers (subject to explicit CBA regulatory approval). | Reduced documentation requirements where expressly permitted by the CBA. |
- Transaction Monitoring & Chainalysis: Providers must deploy real-time monitoring systems. Notably, Armenia’s State Revenue Committee acquired Chainalysis blockchain analytics software in 2024; CASPs should operate under the assumption that all on-chain activity is highly visible to regulators.
- Record Retention: All KYC and transaction data must be retained for a minimum of five years.
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Crypto Tax Framework in Armenia
Armenia’s tax treatment of digital assets remains a significant draw for the jurisdiction, though international reporting standards are imminent.
- Individual Investors: Retail traders who are not operating as systematic, entrepreneurial businesses currently benefit from a 0% effective rate on crypto capital gains.
- Corporate Entities: Licensed CASPs operating as standard companies are subject to an 18% Corporate Income Tax (CIT). Smaller entities qualifying for the special IT sector regime may access a 1% turnover tax.
- Crypto Mining: Mining is strongly supported by the Armenian government. Income is treated as taxable at applicable rates, with the value of mined coins recognized at market price at the exact time of receipt.
- Foreign Investors: Under Armenia’s territorial tax system, non-resident foreign investors trading on local platforms generally face no Armenian tax liability, as their trades are not considered Armenian-source income.
CARF Implementation: What Changes in 2027
Armenia is a signatory to the OECD’s Crypto-Asset Reporting Framework (CARF). Starting in 2027, CASPs will be required to collect and report customer tax residency and transaction data to the State Revenue Committee (SRC).
| What CARF Requires of CASPs | Practical Operational Implication |
| Collect customer tax residency and TIN | Enhanced KYC documentation required at initial onboarding. |
| Report crypto-to-fiat exchanges | All fiat on/off-ramp activity becomes fully reportable. |
| Report crypto-to-crypto exchanges | Cross-asset trading activity becomes fully reportable. |
| Report transfers to/from external wallets | Strict wallet screening and originator tracking required. |
| Annual transmission to tax authorities | Data for tax year 2026 onwards to be reported to SRC from 2027. |
Critical Deadlines & The Cash Transition
The framework outlines strict enforcement deadlines that market participants must observe to avoid forced cessation of operations or criminal liability.
- April 2026 (Legacy Token Issuers): Issuers who conducted public token sales before 31 January 2026 must submit a CBA-compliant offer document (whitepaper) by the end of April 2026.
- July 2026 (The Cash Window Closes): A temporary allowance permits cash-based crypto transactions (up to ~300,000 AMD per trade, with full KYC). After July 2026, the Law on Non-Cash Transactions mandates that all crypto activity be conducted exclusively through electronic methods.
- January 31, 2027 (The Hard Licensing Deadline): Any entity providing crypto-asset services prior to 4 July 2025 must possess a formal CBA license by this date.
FAQs
How long does the licensing application process take?
While the CBA does not publish guaranteed processing times, adequately prepared applications with complete documentation and capital proof are generally processed within 3 to 6 months.
Does an Armenian CASP license grant EU passporting rights?
No. An Armenian license authorizes operations within the jurisdiction but does not provide passport rights to the EU market under MiCA. It serves as a regulated base primarily for global, MENA, or CIS-facing operations.
Can a commercial bank offer crypto services?
Under the current framework, traditional commercial banks wishing to provide crypto-asset services must establish a separate legal entity and apply for a standalone CASP license.
