The digital economy has given rise to new financial models that combine traditional banking and blockchain technologies. One such model is a “crypto bank” — a company that operates with digital assets (tokens), provides custody services, supports cryptocurrency transactions, and integrates blockchain solutions into business processes within the High-Tech Park (HTP) regime in Belarus.
A crypto bank in the HTP is not a traditional bank. It is an HTP resident operating under a specific legal framework for digital assets, with regulatory, compliance, and structural requirements that differ from the traditional banking sector.
Interest in crypto banks is driven by flexible regulation, the ability to work legally with cryptocurrencies, tax incentives, and access to international markets. At the same time, launching such a project requires careful legal structuring and compliance with regulatory requirements.
This article summarizes the concept of a crypto bank in the HTP, its permitted activities, key requirements, and the main legal considerations for establishing and operating such a business in Belarus.
In Belarusian legislation, the concept of a “crypto bank” first appeared in early 2026 alongside the establishment of a legal framework for the functioning of crypto banks as a new type of financial organization.
Regulations define a crypto bank as a joint-stock company that combines operations with digital assets (tokens) with banking, payment, and other financial activities. To enter the market, such a company must:
This means that a crypto bank obtains legal status within the Belarusian financial system and may operate within the boundaries of the special regulatory regime of the HTP.
Unlike a traditional bank, a crypto bank not only stores and redistributes client funds but also combines traditional financial functions with operations related to digital assets. It operates not under a classical banking license but bypassing the requirement for a traditional banking license and on the basis of Decree No. 19 and the requirements established for such companies.
Thus, a crypto bank is a hybrid financial institution that combines elements of traditional banking operations and innovative token-based services while operating within the legal framework of the Republic of Belarus.
The legal status of a crypto bank allows it to carry out operations both with traditional financial instruments and with digital assets (tokens). This creates a legal basis for such services as:
Thus, a crypto bank can act as an intermediary between the classical financial system and the digital asset market.
The core functions of a crypto bank significantly expand the traditional banking toolkit:
A crypto bank acts as a structured service that allows clients to operate digital assets within the legal framework of Belarus.
A crypto bank may serve different categories of clients:
The legal status of a crypto bank and its inclusion in the state register provide clients with additional guarantees of compliance with regulatory requirements and control over the activities of such organizations.
The activities of crypto banks in Belarus are carried out within a specially created legal regime of the HTP, which combines the legal framework of digital economy legislation and Decree No. 19. This approach ensures the legality of operations with digital assets and their integration into the country’s financial system, while maintaining flexibility of regulation and stimulating innovation.
Crypto banks are included in the register of crypto banks of the National Bank of Belarus and in the register of payment service providers. The founders of a crypto bank, before submitting an application for inclusion in the register, must form a charter capital in the amount of at least 20 million Belarusian rubles at the expense of contributions, including by reinvesting profits of other legal entities, both residents and non-residents.
Belarus has become one of the first countries in the world to officially establish the legal status of crypto banks and activities with tokens. Regulation covers:
The regulatory framework is aimed at ensuring the security and transparency of operations, as well as protecting the interests of crypto bank clients.
The High-Tech Park acts as a platform for the development of crypto banks in the country. All companies that intend to operate as a crypto bank with tokens and digital assets must be residents of the HTP, which allows them to benefit from incentives and preferences provided by digital economy legislation.
The HTP provides:
The status of an HTP resident gives a company the right to:
To obtain this status, it is necessary to comply with requirements for corporate structure, staff qualifications, and information security standards. A crypto bank belongs to financial organizations and must comply with all legal requirements established for such companies.
HTP residents, including crypto banks, enjoy the following tax advantages:
Such a system creates favorable conditions for startups and companies seeking to integrate digital assets into their business processes while remaining within the legal framework of the Republic of Belarus.
The legal regime of crypto banks establishes a list of key activities that such organizations may legally carry out within the HTP regime and under the control of the National Bank of the Republic of Belarus.
The key feature of a crypto bank is the combination of traditional banking functions with operations related to digital assets.
A crypto bank may perform basic banking functions similar to those carried out by traditional financial organizations, but bypassing the requirement for a traditional banking license. This includes opening and maintaining client accounts for residents and non-residents, conducting settlement and payment operations, performing currency operations and transfers, providing related settlement services, and forming credit histories.
This is the main technological area that distinguishes a crypto bank from ordinary non-bank financial intermediaries. It includes acceptance, storage, and transfer of tokens, including as a form of settlement, intermediary operations with tokens in settlement chains, and other crypto operations approved by regulators.
A crypto bank may offer products that combine fiat money and digital assets, including accounts that reflect both fiat and tokens, settlements under foreign trade contracts using digital assets (tokens) under certain conditions, and potentially lending secured by tokens.
Crypto banks may implement technological operations necessary for modern digital servicing, including remote client identification and verification, integration with blockchain platforms and smart contracts, and information and technical support of transactions.
It is important to note that the specific list of operations and tokens that a crypto bank may work with is determined by regulators, including decisions of the supervisory board of the HTP and the National Bank.
The establishment and operation of a crypto bank within the HTP legal regime is not just company registration, but compliance with a number of structural, regulatory, and operational requirements that ensure business stability and compliance with financial legislation. The central document is Decree No. 19 “On crypto banks and certain issues of control in the field of digital assets (tokens)”.
To become a crypto bank, an organization must be a joint-stock company, have a stable corporate structure, and comply with the requirements of corporate legislation of the Republic of Belarus. This form ensures transparency of management, distribution of shareholder rights, and responsibility to clients and regulators.
HTP resident status is a mandatory condition for entering the market. Only an HTP resident organization may apply for inclusion in the register of crypto banks maintained by the National Bank. This implies dual control from both the HTP and the National Bank.
Inclusion in the register means that the company has passed verification for compliance with regulatory requirements and is recognized as capable of safely and sustainably conducting crypto transactions and banking activities with digital assets.
A crypto bank must operate in accordance with legislation applicable to non-bank financial institutions, including requirements for capital and financial stability, risk management and internal control regimes, compliance with financial reporting standards, and protection of the rights and interests of clients.
Crypto banks are subject to dual regulation, by the National Bank and the supervisory board of the HTP. This means that along with financial and banking control, technological and innovation regulation is also applied.
Like other participants in the financial market, crypto banks must comply with anti-money laundering and counter-terrorist financing rules, including development of internal procedures, identification and verification of clients, monitoring of transactions, and reporting to regulators.
Since a crypto bank operates with confidential information and digital assets, it must ensure a high level of information security, including secure communication channels, encryption, access control, and data backup. This aspect is critical for maintaining client trust and protection against cyber threats.
The operation of a crypto bank in Belarus is associated with a high level of responsibility and compliance with numerous regulatory requirements. Even with HTP resident status and inclusion in the register, a company must build its activities taking into account financial, technological, and legal compliance, as well as operational risk management.
A crypto bank must implement comprehensive compliance procedures, including:
These measures ensure compliance with legislation and allow the crypto bank to maintain trust of clients and partners.
Even with strict compliance, a crypto bank faces a number of legal limitations:
A crypto bank operates simultaneously with digital and traditional financial instruments, which creates complex risks:
Effective management of these risks requires a combination of financial, technological, and legal control.
Decree No. 19 and HTP requirements impose specific limitations on crypto bank activities:
Thus, compliance, risk management, and adherence to established limitations are integral parts of operating a crypto bank in Belarus.
A crypto bank in the HTP is a new format of financial institution that combines elements of traditional banking services with modern operations involving digital assets. The legal status established by Decree No. 19 and the HTP residency framework create a transparent and lawful environment for working with tokens, ensuring both operational security and access to incentives.
At the same time, successful operation of a crypto bank requires a comprehensive approach, compliance, management of financial and technological risks, organization of internal control, and adherence to regulatory requirements. Without a well-developed strategy and proper legal and financial expertise, working with digital assets may involve significant risks.
Our team advises businesses and investors at all stages, from the creation and support of crypto banks within the HTP to legal, financial, and technological support of token operations. We assess opportunities and risks, develop investment strategies, and build internal compliance procedures and secure client interaction models.
With our support, entry into the digital finance sector becomes a manageable process, businesses gain lawful tools for working with tokens, and investors receive transparent and secure opportunities to participate in innovative projects in Belarus.
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