The Republic of Armenia has recently introduced a comprehensive regulatory framework governing the crypto-asset market. With the adoption of the Law of the Republic of Armenia “On Crypto-Assets” (2025) and subsequent regulatory acts of the Central Bank of Armenia, the country has moved from an essentially unregulated environment toward a structured legal regime for crypto-asset service providers (CASPs), including cryptocurrency exchanges.
This article outlines the key elements of the Armenian crypto-asset regulatory framework, with particular emphasis on the regulation of crypto exchanges and other service providers.
Prior to 2025, Armenia had no dedicated legislation regulating crypto-asset activities. While cryptocurrency transactions were not prohibited, they were largely unregulated and operated in a legal gray zone.
In response to the rapid growth of digital assets and the associated risks of fraud, market manipulation, and money laundering, the Armenian legislature adopted the Law on Crypto-Assets in May 2025. The law entered into force on July 4, 2025 and established the first comprehensive regulatory framework governing crypto-asset markets in Armenia.
The objectives of the legislation include:
- protection of crypto-asset purchasers and clients;
- ensuring transparency and fairness of crypto markets;
- reduction of systemic risks;
- alignment with international regulatory standards.
The regulatory model follows the principle “same activity, same risk, same regulation,” meaning that crypto activities similar to traditional financial services are regulated in a comparable manner.
Legal Framework
The Law of the Republic of Armenia “On Crypto-Assets” regulates the issuance, offering, and servicing of crypto-assets in Armenia.
Pursuant to Article 16 of the Law, crypto-asset services include activities such as:
- operation of crypto-asset trading platforms;
- exchange of crypto-assets for other crypto-assets;
- custody or administration of crypto-assets on behalf of clients;
- execution of crypto-asset transfers;
- crypto-asset advisory services.
Entities providing these services are classified as crypto-asset service providers (CASPs).
Licensing Requirement
Under Article 16 of the Law, crypto-asset services may only be provided by legal entities licensed by the Central Bank of Armenia.
The licensing procedure generally requires:
- disclosure of shareholders and beneficial owners;
- information on management and corporate governance;
- implementation of internal compliance and risk-management policies.
Existing crypto businesses are subject to transitional provisions and must obtain a license within the period established by law.
AML and Compliance
Crypto-asset service providers are subject to Armenian anti-money laundering (AML) legislation.
In particular, CASPs must:
- conduct customer identification (KYC);
- monitor transactions;
- report suspicious activities to authorities;
- maintain transaction records.
These obligations aim to ensure transparency and prevent misuse of crypto-assets for illicit purposes..
Conclusion
The Law on Crypto-Assets establishes a structured regulatory environment for cryptocurrency activities in Armenia. By introducing licensing requirements and regulatory oversight by the Central Bank of Armenia, the new framework aims to promote market transparency while supporting the development of the crypto sector.
Companies planning to operate crypto exchanges or provide related services in Armenia should carefully assess licensing requirements and establish appropriate compliance procedures before entering the market.
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Author:
Aleksand Egibyan
Junior Partner, Legelata Legal and Tax
DISCLAIMER:
This material is produced by or for Legelata LLC. The information contained in this piece is provided for general informational purposes only and does not contain a comprehensive analysis of each item described. Prior to undertaking (or omitting) any action, the reader is advised to seek professional advice tailored to their specific situation. Neither Legelata nor the author accept and hold liability for acts or omissions taken in reliance upon the contents in this material.
LEGELATA LLC 21/11/2025
