MB Legal partners Grigor Grigoryan and Anahit Sargsyan spoke with the business news outlet banks.am about the new regulatory framework governing Armenia’s crypto-asset market.
The discussion centered on the practical application of the Law on Crypto Assets and the secondary legislation adopted by the Central Bank of Armenia. The new framework for crypto-asset licensing in Armenia establishes defined licensing requirements and rules of conduct for a sector that remained largely unregulated for an extended period.
Key points from the interview
The provision of crypto-asset services is now conditional on holding a license. Only legal entities licensed by the Central Bank may carry out such activities.
Two routes into the market are available under the legislation. Existing investment firms may apply for an additional permission, while new entrants must complete the full registration and licensing procedure before the Central Bank.
The law defines ten licensable services, ranging from the operation of a trading platform to the provision of advice. In Grigor Grigoryan’s assessment, the boundaries between these categories are not self-evident in practice, and each business model requires a separate legal analysis.
The transitional period is limited. Market participants already operating as of July 4, 2025 must be registered and licensed by January 31, 2027, or cease providing regulated services.
Armenia is increasingly viewed as a regional platform. As Anahit Sargsyan noted, the firm has been approached by international organizations for which Armenia represents not only a new market, but also a route into the wider CIS region.
Dialogue with the regulator is ongoing. The firm has already held a number of meetings with representatives of the Central Bank concerning matters not yet addressed by the legislation.
Why the framework matters for the market
In Grigor Grigoryan’s assessment, clear and transparent rules are not an obstacle for the sector but a precondition for its development and stability. A regulated environment reduces the risk of abuse and of the laundering of criminally obtained funds, while creating a predictable legal environment for international participants.
At the same time, the legislative framework is still taking shape. The Central Bank’s body of regulations is expected to be expanded during the current year.
The full interview is available on banks.am (in Armenian).
Crypto-asset work at MB Legal
Crypto-asset regulation is among the firm’s most active practice areas. The team has been advising clients in the sector since spring 2026 — investment firms, international crypto platforms and smaller market participants — and takes part in professional discussions on the developing regulatory framework.
The firm advises on the legal assessment of business models, on obtaining a license or additional permission, on company registration and on establishing a branch for foreign organizations. It also prepares internal rules of operation and anti-money laundering and counter-terrorist financing procedures. Related sector context is set out under capital markets and investment funds.
A detailed analysis of the framework — license categories, capital requirements, procedural timelines and questions of liability — is set out in our overview of crypto-asset regulation in Armenia.
Request a consultation
