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Crypto · Regulation

NAPP Approval for Selling a Stake in a Crypto Provider: Rules from 1 October

From 1 October 2026, licensed crypto providers in Uzbekistan may sell stakes and change their director, the director's deputies and the head of the AML/CFT unit only with NAPP approval. An unapproved sale of a stake is a one-time gross violation of license requirements. We break down amendments 3380-3 based on the text on lex.uz: what applied before, what applies now and how to file an application.

· 6 min read · Sogdium Editorial
An empty office chair and a closed matte briefcase on a light podium behind a low barrier with a turquoise cord — illustration for NAPP approval of the sale of a stake and a change of management at a crypto provider

In brief: from 1 October 2026, the sale of a stake in the charter capital of a licensed crypto provider in Uzbekistan (a crypto exchange, crypto store, crypto depository or mining pool) to individuals and legal entities, including non-residents, requires approval from the National Agency of Perspective Projects (NAPP), and an unapproved sale of a stake is classed as a one-time gross violation of license requirements. This is set out in sub-paragraphs (j) and (k) of paragraph 9, sub-paragraph (g) of paragraph 54 and the new Chapter 6¹ of Regulation No. 3380 on the licensing of providers as amended by order of the NAPP director No. 20 of 15 June 2026 (reg. No. 3380-3 of 29 June 2026, in force from 1 October 2026 according to lex.uz). A change of the director, the director's deputies and the head of the AML/CFT unit now also has to be approved by NAPP; the decision takes no more than 10 business days, and no fee is charged.

Which document entered into force on 1 October 2026

  • Base act: Regulation No. 3380 — order of the NAPP director No. 32 of 14 July 2022, reg. No. 3380 of 15 August 2022, in force since 15 August 2022; the current version on lex.uz is dated 1 October 2026.
  • Amendments: order of the NAPP director No. 20 of 15 June 2026, reg. No. 3380-3 of 29 June 2026; published in the National Database of Legislation on 30 June 2026 (the publication number on lex.uz contains a typo, "3880-3"); in force from 1 October 2026.
  • Regulator's announcement: NAPP wrote on 30 June 2026 that the amendments "will enter into force three months after the date of their official publication" (translated from Russian). The agency named the goal as implementing the FATF Recommendations "on preventing criminals from managing and owning service providers" (translated from Russian) and linked the amendments to Presidential Resolution PQ-143 of 17 April 2026 (in force since 20 April 2026).

NAPP has not published a separate announcement on the amendments entering into force (napp.uz news and announcements, Telegram channel @napp_uz for 30 September – 2 October 2026, checked on 2 October 2026).

What has changed for crypto providers: before and after

A comparison of the versions of Regulation No. 3380 of 3 June 2026 and 1 October 2026 on lex.uz (retrieved 2 October 2026).

ProvisionBefore (version of 3 June 2026)After (from 1 October 2026)
Sale of a stake (para. 9(j), para. 54¹, para. 54(g))Regulation No. 3380 as amended on 3 June 2026 (lex.uz, retrieved 2 October 2026) contained no approval requirementSale of a stake to individuals and legal entities, including non-residents — subject to NAPP approval; failure to obtain approval is a one-time gross violation
Change of management (para. 9(k), para. 54¹)Regulation No. 3380 as amended on 3 June 2026 (lex.uz, retrieved 2 October 2026) contained no approval requirementNAPP approval of a change of the director, the director's deputies and the head of the AML/CFT unit; not included in the list of gross violations in para. 54
Who may not serve as manager (para. 9(h), para. 54(b))Persons involved or suspected of involvement in terrorism or the proliferation of WMD; persons with an unexpunged or outstanding criminal record for economic crimes, money laundering, terrorism and WMD proliferation and their financing, organized crime, illegal drug trafficking, corruption and IT crimes. At the same time, para. 6(a) of PQ-3832 as amended by PQ-143 had since 20 April 2026 already prohibited management by persons permanently residing, located or registered in states that do not participate in international AML/CFT cooperationPersons involved or suspected of involvement in terrorism or the proliferation of WMD; "suspects with an unexpunged or outstanding criminal record" (translated from Russian) for economic crimes, money laundering, terrorist financing and proliferation financing, organized crime, illegal drug trafficking, corruption and IT crimes; plus persons permanently residing, located or registered in states that do not participate in international AML/CFT/CPF cooperation; para. 6(a) of PQ-3832 (of 3 July 2018, as amended by PQ-143 from 20 April 2026) still names a criminal record for terrorism and WMD proliferation and their financing
Who may not hold capital (para. 9(i), para. 54(c))Persons under sub-paragraph (h), as well as companies registered "in offshore zones" (translated from Russian); at the same time, para. 6(b) of PQ-3832 as amended by PQ-143 had since 20 April 2026 already prohibited participation by companies from states that do not participate in AML/CFT cooperationPersons under sub-paragraph (h) and companies registered in states that do not participate in international AML/CFT/CPF cooperation; the words "offshore zones" do not appear in the text of the Regulation on lex.uz as of 2 October 2026
Reconsideration of a license application (para. 31)New grounds for refusal may not be cited, except those related to the documents on eliminating the earlier grounds and the cases in the sixth indent of para. 24 (information on the involvement or suspected involvement of the applicant's officers and founders in the crimes listed in sub-paragraph (h) of para. 9)The same, plus the seventh indent of para. 24 — a reasoned judgment of the licensing authority

The text of Regulation No. 3380 contains no list of states that "do not participate in international cooperation" and no reference to FATF lists (lex.uz, version of 1 October 2026, checked on 2 October 2026). Spot.uz on 30 June 2026 equated such countries with the FATF black and grey lists — this is the outlet's interpretation.

How to get approval for a stake sale or a change of director: the Chapter 6¹ procedure

Under paragraph 54², the provider submits to NAPP:

a) an application stating its name and legal form, postal address, taxpayer identification number (TIN), e-mail, bank and settlement account, and the purpose of the application (sale of a stake or a change of the director, the director's deputies or the head of the AML/CFT unit); b) information on the individual, including the prospective buyer of the stake (full name, identity document number, PINFL); for foreign citizens — additionally, the certificate under sub-paragraph (d); c) information on the management and founders of a legal entity that is the prospective buyer, using the new Appendix No. 3, with the chain of founders up to and including the ultimate beneficial owner; d) for foreign citizens who are managers and founders of the buying legal entity — a certificate from a competent authority of the foreign state confirming the absence of a criminal record for the crimes listed in sub-paragraph (h) of para. 9, legalized or apostilled, with a notarized translation into the state language.

Decision (paras. 54³, 54⁴):

  • a decision to approve or refuse — no later than 10 business days from the date the application is received;
  • if the persons meet the license requirements, NAPP grants approval; if they do not, "and also in accordance with a reasoned judgment, approval is refused" (translated from Russian);
  • the licensee is notified within one business day;
  • "No fee is charged for considering the application and making a decision" (translated from Russian).

What an unapproved sale of a stake can lead to

Sub-paragraph (g) of paragraph 54 classes as a one-time gross violation "failure to obtain the licensing authority's approval for the sale to individuals and legal entities, including non-residents, of a stake in the licensee's charter capital" (translated from Russian). Under the seventh indent of paragraph 50 of the Regulation, a one-time gross violation under paragraph 54 is one of the grounds for revoking a license; under paragraph 51, in that case the license is revoked by a court. After such a revocation, a license is not reissued for one year, and this requirement extends to "new business entities established by the founder or beneficial owner of the licensee" (translated from Russian) (the ninth indent of para. 50, in force since 8 May 2024).

An unapproved change of the director, deputies or the head of the AML/CFT unit is not included in the list in paragraph 54: under the twelfth indent of para. 54, violations of requirements outside sub-paragraphs (a)–(g) (until 1 October 2026 — (a)–(f)) are systematic if committed two or more times within a year. A systematic violation is grounds for revocation of the license by a court and a one-year ban on obtaining a new license (the seventh and ninth indents of para. 50, para. 51). If violations of license requirements are detected, including of sub-paragraphs (j) and (k) of para. 9, the license may be suspended (para. 39).

Who is affected

Paragraph 9 and Chapter 6¹ apply to all four types of licensees. According to the NAPP license register (napp.uz/ru/pages/erlsp, retrieved 2 October 2026), the table of active licenses contains 21 entries for 16 legal entities: 2 crypto exchanges, 6 crypto depositories and 13 crypto stores, of which 5 stores are marked as suspended for six months; there are no mining pool licenses.

Foreign platforms without a NAPP license are not covered by the Chapter 6¹ rules: a license is issued exclusively to legal entities that are residents of Uzbekistan (para. 3 of Regulation No. 3380).

Another change this week: amendments to the AML/CFT rules entered into force on 29 September 2026

The amendments to the Internal Control Rules on AML/CFT for crypto providers (reg. No. 3309 of 9 June 2021) are a joint resolution of NAPP and the Department for Combating Economic Crimes under the Prosecutor General's Office (DCEC), reg. No. 3309-3 of 28 September 2026. NAPP reported on 28 September 2026 that the resolution "passed state registration on 28 September 2026 and enters into force on the day of its official publication" (translated from Russian); according to the lex.uz card, it has been in force since 29 September 2026 (the publication was also reported by Spot.uz on 30 September 2026). As of 2 October 2026, the text of the amendments has not been posted on lex.uz: the 3309-3 card has no text, and the consolidated version of Rules No. 3309 is dated 13 July 2022. For the substance, see our breakdown of 29 September 2026: it was prepared on the basis of the final text of the draft and has not been checked against the published text.

FAQ

Does the sale of a stake in an Uzbek crypto exchange need NAPP approval? Yes, from 1 October 2026: sub-paragraph (j) of paragraph 9 and paragraph 54¹ of Regulation No. 3380 (as amended by 3380-3) require NAPP approval for the sale of a stake in a licensee's charter capital to individuals and legal entities, including non-residents. The requirement applies to all four types of licensees, including crypto stores and crypto depositories.

How long does NAPP take to consider an application to approve a stake sale or a change of director? No more than 10 business days from the date the application is received (para. 54³ of Regulation No. 3380 as amended from 1 October 2026); no fee is charged (para. 54⁴).

What happens if a crypto exchange sells a stake without NAPP approval? From 1 October 2026, this is a one-time gross violation of license requirements (para. 54(g) of Regulation No. 3380). Under paragraphs 50 and 51 of the Regulation, it is a case for revocation of the license by a court; after revocation, a license is not reissued for one year, including to "new business entities" (translated from Russian) established by the founder or beneficial owner of the licensee (the ninth indent of para. 50).

Can a foreigner buy a stake in an Uzbek crypto provider? Yes, with NAPP approval: sub-paragraph (j) of paragraph 9 names non-residents among possible buyers, and para. 54²(b) provides for an additional certificate for foreign citizens. Foreign managers and founders of a buying legal entity submit a legalized or apostilled certificate confirming the absence of a criminal record, with a notarized translation (para. 54²(d)). Persons permanently residing, located or registered in states that do not participate in international AML/CFT cooperation, and companies registered in such states, are not allowed to hold capital (para. 9(i) as amended from 1 October 2026).

Are offshore companies banned from the capital of Uzbek crypto exchanges from 1 October 2026? Regulation No. 3380 no longer mentions offshore zones from 1 October 2026: sub-paragraph (i) of para. 9 bars from the capital companies registered in states that do not participate in international AML/CFT/CPF cooperation; the Regulation contains no list of such states (lex.uz, version of 1 October 2026, checked on 2 October 2026). In the version of 3 June 2026, the same sub-paragraph barred companies registered "in offshore zones" (translated from Russian). At the level of PQ-3832 (of 3 July 2018, as amended by PQ-143 from 20 April 2026, para. 6(b)), the ban on participation by companies from such states has applied since 20 April 2026.

Can NAPP refuse approval on the basis of a reasoned judgment? Yes: under para. 54³ of Regulation No. 3380 (as amended from 1 October 2026), NAPP refuses approval if the persons do not meet the license requirements, "and also in accordance with a reasoned judgment" (translated from Russian).

Sources

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