Regulatory and licensing support for businesses seeking authorisation to provide crypto-asset services in Armenia.
From service classification and applicant structuring to AML/CFT, governance, business-plan and application preparation, the licensing workstream is aligned with the requirements of the Central Bank of Armenia.
For the standard local applicant route, the CBA framework uses an Armenian LLC or JSC and links licensing requirements to the services, ownership, capital, management and business plan of the applicant. A qualifying foreign crypto-asset business may instead seek CBA authorisation for an Armenian branch under the separate foreign-company route.
Registration, licensing and ongoing supervision of CASPs under the Armenian crypto-asset framework.
The standard locally incorporated applicant is established in Armenia as an LLC or JSC. A qualifying foreign crypto-asset business may use the separate CBA-authorised branch route where the statutory conditions are met.
Foreign shareholders may participate, subject to CBA review of qualifying holdings, control and source of funds where applicable.
CBA service floors range from AMD 10 million for advice to AMD 200 million for asset-referenced-token issuance, subject to the higher-of fixed-cost and reserve-assets tests.
The minimum total capital threshold is not simply the nominal share capital. Under CBA Regulation 7/02, the CASP must meet the highest applicable threshold, including the service floor and 25% of fixed costs; asset-referenced-token issuers also face a reserve-assets test.
Entity formation alone is not the service. The licence file must reconcile owners, managers, financial resources, AML/CFT, internal controls, technology, outsourcing and business-plan assumptions.
Armenian law permits companies to be wholly foreign-owned. For a regulated CASP, however, ownership is not merely a corporate-registration question: qualifying holders, source of funds, control and management must be acceptable to the Central Bank. A foreign licensed crypto business may also consider an Armenian subsidiary or, where the statutory conditions are met, a CBA-authorised branch.
Foreign individuals and foreign legal entities may own an Armenian company, including 100% foreign ownership under the general investment framework. For a CASP, qualifying holdings are subject to CBA prior-consent rules and source-of-funds / suitability review. The Crypto-Assets Law does not impose a blanket Armenian-citizenship requirement on executive officers; managers are instead subject to CBA registration and fit-and-proper requirements. The final governance and local-substance model should be confirmed for the selected services.
Armenian resident companies are generally subject to 18% corporate profit tax. The standard VAT rate is 20%. The Tax Code expressly treats crypto-asset services as services for VAT purposes, while the alienation of crypto-assets itself is VAT-exempt; the VAT treatment of fees, commissions and cross-border services should therefore be tested by transaction type and place-of-supply rules. CASPs are excluded from Armenia’s turnover-tax regime.
Focused assessment of the proposed service model and critical CBA licensing dependencies.
Coordination of the Armenian applicant structure and corporate workstream in line with the intended licence.
Regulatory and compliance file preparation aligned to the selected service categories.
Implementation support connecting approved policies and licence conditions with the operating business.
The Armenian regime is new enough that the file should be built conservatively around the CBA’s published requirements and actual operating evidence rather than aggressive assumptions about speed, tax or “MiCA-equivalence”.
The selected CASP services are mapped to the applicant, governance, capital and documentation workstream.
Risk assessment, KYC/CDD, sanctions, monitoring and reporting are integrated with the service model.
Regulatory and compliance support can be coordinated in Armenian, Russian and English, reducing translation and implementation friction.
Formal Armenian legal representation, reserved local work and CBA filing steps are coordinated with appropriately qualified local counsel where required.
Identify the regulated CASP functions and customer/transaction flows.
Review entity, owners, managers, capital and key readiness gaps.
Prepare business, AML/CFT, governance, technology and internal-control documentation.
Work with local counsel/partners on formal CBA submission and information requests.
Connect approved documentation with controls, staff, vendors and ongoing supervision.
Scope depends on the regulated services, applicant structure, capital and business-plan requirements, AML/CFT build, technology documentation and local professional inputs. Government/state duties, company formation, office, local counsel, staff, audit, technology and banking costs are separate unless expressly included.
For the standard local route, the applicant is an Armenian LLC or JSC subject to CBA registration and licensing. The Crypto-Assets Law also permits a qualifying foreign crypto-asset company to operate through an Armenian subsidiary or, where the statutory conditions are met, a CBA-authorised branch.
Yes. Armenian law permits wholly foreign-owned companies, and the Crypto-Assets Law also recognises subsidiary and branch routes for foreign crypto businesses. For a CASP, qualifying shareholders remain subject to Central Bank prior-consent, source-of-funds and suitability requirements.
The general corporate profit tax rate is 18% and the standard VAT rate is 20%. Crypto-asset service providers cannot use the turnover-tax regime. The alienation of crypto-assets is VAT-exempt, but CASP service fees and commissions require a separate VAT and place-of-supply analysis.
Providers that were operating in Armenia on 4 July 2025 must be registered and licensed by the CBA by 31 January 2027 or cease providing/offering the regulated services.
No. Armenia is not an EU/EEA member state and the CBA licence does not create MiCA passporting rights.
No. The regime is relatively new and regulator timing can depend on application completeness, service complexity and information requests.
Yes. The LEX ARTA workstream can be coordinated in Armenian, Russian and English; formal Armenian legal work is assigned to appropriately qualified local professionals where required.
Map the exact CBA service scope and applicant readiness before building the full regulatory and AML/CFT file.
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