Fines for Foreign Crypto Exchanges in Uzbekistan: NAPP Draft up to 11bn Soums
A draft NAPP regulation proposes fining foreign companies that provide crypto services to residents of Uzbekistan without a license up to 25,000 BCV — 11 billion soums at a BCV of 440,000 (since 1 September 2026). The consultation closed on 13 August 2026, and as of 26 September 2026 there is no order in the lex.uz database. The amounts, the procedure and what it means for users.
In brief: as of 26 September 2026, fines for foreign crypto exchanges in Uzbekistan exist only as a draft: on 3 August 2026, the National Agency of Perspective Projects (NAPP) published on regulation.adliya.uz a draft Regulation on the procedure for imposing fines on foreign legal entities that provide illegal services in the field of crypto asset circulation to residents of Uzbekistan. The largest amount in the appendix to the draft is 25,000 BCV for operating without a license, i.e. 11 billion soums at a BCV of 440,000 soums (since 1 September 2026 under Presidential Decree PF-115 of 23 June 2026). The public consultation ran from 3 to 13 August 2026; as of 26 September 2026, there is no registered order in the lex.uz database (searched by the draft's title and among acts on crypto assets). The fines target companies — users are liable under Article 155-4 of the Code of Administrative Liability and, for a repeat offense or aggravating circumstances, under Article 278-8 of the Criminal Code.
Status of the draft as of 26 September 2026
| Parameter | Data (portal API and lex.uz, retrieved 26 September 2026) |
|---|---|
| Developer, type of act | NAPP, order of the director |
| Consultation | 3–13 August 2026, closed; 0 proposals |
| Text versions | 3 August and 8 August 2026, the provisions are identical |
| Entry into force | under para. 2 of the draft order — "from the day of its official publication" (translated from Russian) |
| Registration with the Ministry of Justice | not found in the lex.uz database as of 26 September 2026; the latest NAPP-related act on crypto assets found there is No. 3388-2 (reg. 27 July 2026) |
Until the order is registered and published, everything below is the developer's proposal. Quotes are from the Russian version of the draft and are translated from Russian (the draft has no English version); paragraph numbers are as on the portal: paras. 1–2 of the draft order, paras. 1–18 of the draft Regulation.
Who drafted it and on what basis
The preamble of the draft refers to PQ-3150 of 27 July 2017 on organizing the activities of NAPP (in force since 31 July 2017, last amended by PF-65 of 17 April 2026, lex.uz) and PQ-3832 of 3 July 2018 (as amended by PQ-143 from 20 April 2026, lex.uz).
The power in this wording appeared in para. 5(b) of PQ-3832 as amended by PQ-143 of 17 April 2026 (NAPP's general right to impose fines existed earlier — under PQ-3150 of 27 July 2017, which the preamble of the draft cites; the order against Binance dates from 2024). NAPP is entitled to:
- "conduct inspections of the activities of foreign legal entities that illegally provide services to residents of the Republic of Uzbekistan in the field of crypto asset circulation" — without applying the acts on state control over business entities (translated from Russian);
- "apply penalties to foreign legal entities for violations of legislation in the field of crypto asset circulation. In this case, 50 percent of the fine amount is transferred to the account of the licensing authority" (translated from Russian).
The draft specifies: 50% of the fine goes to the state budget and 50% to NAPP's treasury personal accounts (para. 2).
This model already operates for gambling: NAPP Regulation No. 3643 on fines for foreign online gaming operators (reg. 7 July 2025, in force since 9 October 2025, lex.uz) has the same five chapters and also sets 25,000 BCV for operating without a license (para. 1 of Appendix 2; text available only in Uzbek).
Who the draft fines apply to
There is no separate definition. The scope is set in para. 3 of the draft: "foreign legal entities providing illegal services in the field of crypto asset circulation to residents of the Republic of Uzbekistan" (translated from Russian). The draft does not define "resident" or the types of services (both versions on the portal, 26 September 2026).
When a transaction is deemed to take place in Uzbekistan is determined by para. 5(a) of PQ-3832 (as amended by PQ-143): at least two of five conditions must be met — a party to the transaction is a resident of Uzbekistan; the transaction is carried out in its territory; the IP address or phone number is Uzbek; settlements are made with a card of a bank of Uzbekistan, or payments are processed and cleared in Uzbekistan; the services are intended for residents of Uzbekistan, "in particular, they are provided or advertised in the state language" (translated from Russian). The draft does not refer directly to this subparagraph — it refers to PQ-3832 as a whole.
Fine amounts under the draft: from 4.4 to 11 billion soums
Calculation: 25,000 BCV × 440,000 soums = 11,000,000,000 soums. The BCV of 440,000 soums was set from 1 September 2026 by para. 3(b)(ii) of Presidential Decree PF-115 of 23 June 2026 (in force since 23 June 2026, lex.uz). Dollar amounts are at the Central Bank of Uzbekistan rate of 11,825.40 soums as of 26 September 2026 (cbu.uz).
| Violation (appendix to the draft) | BCV | Soums at a BCV of 440,000 | ≈ $ at the central bank rate on 26 September 2026 |
|---|---|---|---|
| Activity in the field of crypto asset circulation in Uzbekistan without a license | 25,000 | 11 billion | $930k |
| Failure to comply with requirements for storing and using personal data | 15,000 | 6.6 billion | $558k |
| Violation of legislation on countering the legalization of criminal proceeds, the financing of terrorism and the financing of the proliferation of weapons of mass destruction (AML/CFT) | 15,000 | 6.6 billion | $558k |
| Violation of advertising requirements in the field of crypto asset circulation | 10,000 | 4.4 billion | $372k |
Under the draft, fines "are calculated in the national currency" (para. 2; translated from Russian), but the draft does not specify which date's BCV applies (both versions on the portal, 26 September 2026). Payment "does not release" the company from liability for the violation of legislation (para. 3; translated from Russian).
Procedure under the draft: a commission, a decision and 15 days to pay
Under the draft, the procedure is as follows:
- Sources of information (para. 4) — including inspections by NAPP and law enforcement agencies, reports, auditors' opinions, complaints from individuals and legal entities, and information from providers.
- What is taken into account (para. 5) — systematic nature (two or more times) and duration; the impact on transaction participants; whether a fine can change the situation; the causes of the violations; the effectiveness of previous fines; measures taken by the company on its own.
- Who decides (paras. 6–8) — the NAPP director or a deputy acting in that capacity, based on the opinion of a Working Commission made up of an odd number of NAPP employees.
- Limitation period (para. 9) — no more than six months from the date of detection (the date of the commission's opinion) and three years from the date the violation was committed.
- Participation (para. 10) — the company is notified of the meeting five working days in advance, and its representative may take part.
- Payment (paras. 11–12) — an extract from the decision is sent within three working days, and payment is due within 15 days of receiving written notice; in case of non-payment, under the draft NAPP "applies to the court to collect the fine" (translated from Russian).
- Publicity (para. 13) — NAPP may report violations and fines to the media.
Appeals under the draft (paras. 14–17). Within 15 days of receiving the extract — a complaint to the NAPP Appeals Council or a lawsuit in court. The Council reviews the complaint within 15 days; the payment deadline is suspended for the duration of the appeal.
How to collect a fine from a non-resident, and where blocking comes in
The only enforcement tool in the draft is the court (para. 12); the text does not say which court or how the decision would be enforced abroad (both versions, 26 September 2026). The draft does not mention website blocking (both versions on the portal, 26 September 2026) — that is a separate mechanism.
- Grounds for blocking — the NAPP FAQ (retrieved 26 September 2026) cites, among other things, para. 1 of Cabinet of Ministers Resolution No. 707 of 5 September 2018 (in force since 6 September 2018, last amended by Cabinet of Ministers Resolution No. 791 of 15 December 2025, lex.uz): access is restricted when a website is used for "committing other actions entailing criminal and other liability in accordance with the law" (translated from Russian).
- 9 August 2022 — the websites of Binance, FTX and other exchanges began opening with a block page referring to Cabinet of Ministers Resolution No. 707; NAPP attributed this to the lack of licenses (Gazeta.uz, 11 August 2022).
- 4 January 2024 — NAPP reported a penalty order against Binance for 300 BCV (102 million soums at the time it was imposed), including for providing services to Uzbek residents without a license (Spot, 4 January 2024).
- 18 March 2026 — NAPP First Deputy Director Vyacheslav Pak, as reported by Spot, answering a question from a Kursiv Uzbekistan correspondent about combating illegal activity, said that 3–4 foreign platforms had been fined in 2025: they agreed to pay but asked not to be named (translated from Russian). The same report says that in 2025 NAPP requested the blocking of more than 3,000 resources — according to Spot, this figure includes not only crypto platforms but also marketplaces, bookmakers and online casinos.
Fines for companies vs. liability for users: the difference
| Foreign company | Resident user | |
|---|---|---|
| Provision | NAPP draft (3 August 2026), based on para. 5(b) of PQ-3832 | Article 155-4 of the Code of Administrative Liability, Article 278-8 of the Criminal Code — introduced by Law No. ZRU-899 of 19 January 2024, in force since 20 April 2024 (lex.uz) |
| Penalty | 10,000–25,000 BCV (4.4–11 billion soums at a BCV of 440,000) | Article 155-4, part 1: detention of up to 15 days or, for persons to whom detention does not apply, a fine of 20–30 BCV (8.8–13.2 million soums at a BCV of 440,000), with confiscation; Article 278-8 — up to 5 years of deprivation of liberty (part 3) |
| Status as of 26 September 2026 | draft | in force |
Details are in our breakdown "Fines for Crypto in Uzbekistan".
What it means for Binance, Bybit and OKX users
- No licenses. As of 26 September 2026, the NAPP license register has no entries for Binance, Bybit or OKX; the licensed exchanges as of 26 September 2026 are COINPAY and ASTERIUM (breakdown of the register).
- Binance — only via COINPAY. On 29 January 2025, NAPP stated that residents "must use the services of the Binance crypto exchange exclusively by following the link provided on the official page of CoinPay LLC" (translated from Russian), and that transactions directly on Binance P2P are a violation. On 11 February 2026, Podrobno.uz relayed a NAPP reminder: P2P deals "entail liability under the law" (translated from Russian). More in our COINPAY review.
- The draft does not affect user accounts: it contains no provisions on client accounts, funds or withdrawals (both versions, 26 September 2026). Neither the draft, nor NAPP, nor Spot and Podrobno in the publications checked say how service for Uzbek residents on a particular platform would change if the order is adopted (26 September 2026).
FAQ
What fines do foreign crypto exchanges face in Uzbekistan? Under the NAPP draft of 3 August 2026 — from 10,000 to 25,000 BCV, i.e. 4.4–11 billion soums at a BCV of 440,000 soums (since 1 September 2026). The largest under the draft, 25,000 BCV, is for operating without a license.
Has the regulation on fines for foreign crypto exchanges been adopted? As of 26 September 2026 — no: no registered order was found in the lex.uz database (searched by title and among acts on crypto assets). The consultation on regulation.adliya.uz ran from 3 to 13 August 2026; under the draft, the order will enter into force on the day of its official publication.
Will Binance users be fined under this regulation? No: under the text of the draft (both versions on the portal, 26 September 2026), the fines apply only to foreign legal entities. A resident user who trades outside licensed providers is liable under Article 155-4 of the Code of Administrative Liability and Article 278-8 of the Criminal Code.
How will NAPP collect a fine from a foreign company? Under the draft — payment within 15 days of written notice; otherwise NAPP applies to the court (paras. 11–12). The draft does not say how the decision would be enforced abroad (text on the portal, 26 September 2026).
Can a NAPP fine be appealed? Yes, under the draft — within 15 days of receiving the extract: a complaint to the NAPP Appeals Council or a lawsuit in court. The payment deadline is suspended for the duration of the appeal.
Has NAPP fined foreign crypto platforms before? Yes: NAPP reported a penalty order against Binance for 300 BCV on 4 January 2024 (Spot). According to Vyacheslav Pak on 18 March 2026 (answering a question from a Kursiv Uzbekistan correspondent, as reported by Spot), 3–4 foreign platforms were fined in 2025, and their names were not disclosed.
Sources
- Draft NAPP order and Regulation on fines for foreign legal entities — regulation.adliya.uz, published 3 August 2026
- PQ-3832 of 3 July 2018, as amended by PQ-143 — lex.uz; PQ-3150 of 27 July 2017 — lex.uz; PF-115 of 23 June 2026 — lex.uz
- NAPP Regulation No. 3643 (gambling), available only in Uzbek — lex.uz; Cabinet of Ministers Resolution No. 707 of 5 September 2018 — lex.uz; Law No. ZRU-899 of 19 January 2024 — lex.uz
- NAPP: FAQ (retrieved 26 September 2026); license register (retrieved 26 September 2026); statement on Binance P2P, 29 January 2025
- Central Bank of Uzbekistan exchange rate as of 26 September 2026 — cbu.uz API
- Spot, 3 August 2026; Spot, 18 March 2026; Spot, 4 January 2024; Gazeta.uz, 11 August 2022; Podrobno.uz, 11 February 2026
