Crypto Banks in Belarus: What Presidential Decree No. 19 Means for Your Business

A crypto bank in Belarus - is a joint-stock company that, under Presidential Decree No. 19 of 16 January 2026 "On Crypto Banks and Certain Issues of Control in the Sphere of Digital Tokens", is authorised to combine licensed banking and payment operations with activities involving digital tokens within a single regulated structure. This hybrid model is entirely new to Belarusian financial law and creates both significant commercial opportunities and concrete legal obligations for founders, investors and corporate clients operating in or with Belarus.

What Makes a Crypto Bank Different from a Conventional Bank or Crypto Platform

Prior to Decree No. 19, Belarusian law maintained a strict separation between the banking sector and the digital asset market. Licensed banks operating under the Banking Code of the Republic of Belarus had no authority to conduct token transactions; crypto platform operators — residents of the High Technologies Park (HTP) established under Presidential Decree No. 8 of 21 December 2017 "On the Development of the Digital Economy" — were equally barred from providing banking services. Any business requiring both capabilities was forced to operate through multiple legal entities, multiplying compliance costs and contractual complexity.

A crypto bank dissolves this separation. It holds a single organisational form — the joint-stock company — yet operates under a dual supervisory regime: the National Bank of the Republic of Belarus oversees its prudential soundness as a non-banking credit and financial institution, while the HTP Supervisory Board monitors its compliance with the conditions of HTP residency. For corporate clients, this means conducting token settlements and conventional financial transactions within one contractual relationship, without intermediary chains.

How to Obtain Crypto Bank Status: the Two-Track Licensing Process

Access to the crypto banking market requires simultaneous compliance with two regulatory tracks. First, the organisation must obtain HTP resident status under Presidential Decree No. 12 of 22 September 2005 "On the High Technologies Park". Second, it must be included in the dedicated register of crypto banks maintained by the National Bank of the Republic of Belarus. Neither condition is sufficient on its own: both must be satisfied before the organisation may lawfully operate as a crypto bank.

Detailed requirements — including minimum authorised capital, fit-and-proper standards for management, and reporting obligations — will be established by subordinate regulations of the National Bank within the transitional period provided for under Decree No. 19. The register and all relevant updates are published on the official website of the National Bank at www.nbrb.by. Businesses planning to enter this market should begin corporate preparation now rather than waiting for the full regulatory package to be in place.

Why Tax and Accounting Treatment Matters from Day One

For corporate clients and founders alike, the accounting and tax implications of crypto bank operations are among the most practically significant aspects of the new regime. Under the National Accounting Standard "Digital Tokens (Digital Signs)", approved by Resolution No. 16 of the Ministry of Finance of 6 March 2018, legal entities are required to recognise tokens as a distinct category of asset and apply specific rules for initial measurement, subsequent revaluation and derecognition.

The valuation of a token at the date of each transaction is a particular compliance risk: unlike foreign currency, for which the National Bank publishes official exchange rates, token pricing may be based on crypto bank quotations or contractually agreed benchmarks. An organisation's accounting policy must expressly establish the methodology for token valuation and documentation of each operation before commencing activity, to avoid disputes with tax authorities during subsequent audits.

From a tax perspective, income from token transactions for legal entities is subject to the Tax Code of the Republic of Belarus. The applicability of the preferential tax regime available to HTP residents under Decree No. 8 to operations conducted through a crypto bank will be clarified by forthcoming subordinate legislation. Until that clarification is issued, companies should apply existing Tax Code provisions and monitor official guidance published by the Ministry of Taxes and Levies at nalog.gov.by.

What Cross-Border Investors and Foreign Business Partners Should Consider

Decree No. 19 explicitly permits the use of digital tokens as a settlement instrument in foreign trade agreements conducted through crypto banks. This is a meaningful development for international business: prior to this reform, token-denominated cross-border settlements by Belarusian companies either lacked a clear legal basis or required special authorisation under foreign exchange legislation.

Foreign investors participating in the capital of a Belarusian crypto bank must comply with the Law of the Republic of Belarus No. 53-Z of 12 July 2013 "On Investments", which guarantees profit repatriation rights but imposes procedural requirements for the registration of foreign investments. Cross-border structuring also requires analysis of the applicable double taxation treaty, where relevant, and careful attention to foreign exchange control obligations under the Law of the Republic of Belarus "On Foreign Exchange Regulation and Foreign Exchange Control". In complex cross-border arrangements, engaging qualified legal counsel at the structuring stage significantly reduces the risk of subsequent regulatory exposure. 

When Full Implementation Takes Effect and What Business Should Do Now

The provisions of Decree No. 19 enter into full force on 18 July 2026, with certain provisions already in effect from the date of official publication on 25 January 2026. The transitional period is not a reason for inaction: it is the optimal window for corporate audit, updating accounting policies, preparing internal compliance frameworks and assessing HTP eligibility. 

Law firm «Economic Disputes» has been advising B2B clients on financial regulation, cross-border transactions and digital economy matters since 2019. Our team comprises 15 lawyers and specialists with between fifteen and twenty-five years of professional experience. The firm's managing partner, Sergei Belyavsky, brings twenty years of practice in economic courts — including ten years as a judge — and serves as a recommended arbitrator of the International Arbitration Court at the Belarusian Chamber of Commerce and Industry, as well as an arbitrator in other arbitration bodies. He is the author of five books and more than two thousand publications on commercial law. The firm operates four mediators and its own arbitration tribunal "Spory gospodarcze".

To date, we have served more than two thousand clients and have recovered or saved in excess of 1.95 billion Belarusian roubles. Our average client rating is 4.95 out of 5 across more than one hundred verified reviews. We work in Russian, Polish and English, maintain a partner network spanning more than 160 countries and have been a member of AEA since June 2025. Our offices are located in Minsk (11 Kulman Street) and Grodno (23 Kalyuchinskaya Street); the firm holds a settlement account with PKO Bank Polski for clients operating in the Polish and wider European market.

If your business requires legal support in connection with crypto bank licensing, HTP residency, digital asset compliance or cross-border settlement structuring, please submit an enquiry — we will propose a realistic action plan tailored to your situation.