Regional jurisdiction · regulator: Central Bank of Armenia

Armenia CASP licence

A MiCA-style licence from a real central bank. Armenia’s crypto-asset framework went live in 2025 — licensing has been mandatory for new providers since 31 January 2026, and the early-mover window is open.

Licence: Crypto-Asset Service Provider (CASP), Central Bank of Armenia
Timeline: ≈2–3 months CBA review; 3–5 months end to end
Capital: From ≈US $26k (advisory) to ≈US $182k (trading platform)
Best for: OTC desks, exchanges and platforms serving the CIS region

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Scope

What the licence covers

Armenia’s Law on Crypto-Assets (adopted May 2025, in force since July 2025) follows the EU’s MiCA architecture: one CASP licence from the Central Bank of Armenia, with permissions per activity. The Central Bank’s implementing regulations took effect on 31 January 2026 — since then, providing crypto-asset services in Armenia requires a licence.

Operating a crypto-asset trading platform
Exchange of crypto-assets for fiat or other crypto-assets
Custody and administration of crypto-assets
Execution, reception and transmission of client orders
Own-account dealing and placement of crypto-assets
Portfolio management and advisory on crypto-assets

Roughly ten regulated activity types in total — your permission set defines your capital requirement, so we scope it to what you actually do.

Requirements

Capital and substance

Entity	Armenian company licensed by the Central Bank
Capital — advisory	AMD 10M ≈ US $26,000
Capital — orders, transfers, portfolio mgmt	≈AMD 20M ≈ US $52,000
Capital — dealing & custody	≈AMD 50M ≈ US $130,000
Capital — trading platform	AMD 70M ≈ US $182,000
KYC/AML	Compliance programme aligned with CBA regulation; non-cash transactions only
Management	Fit-and-proper review of shareholders and executives by the CBA

The highest tier among your chosen activities governs, and capital must be deposited in an Armenian bank. An annual state duty also applies — we confirm the current amount when scoping your application.

Timeline & cost

How long, how much

Incorporate & capitalise

Armenian entity, capital deposited in a local bank, compliance documentation drafted to CBA standards.

File with the CBA

Licence application with your chosen activity set. The Central Bank’s review runs about 2–3 months.

Licence granted

You operate as a regulated CASP under central-bank supervision — a strong signal for banks and counterparties.

End to end, plan for 3–5 months including company formation. The real budget driver is regulatory capital, not fees — which is why choosing the right activity set matters.

OTC · P2P · cash

The fine print that matters

OTC and P2P desks

OTC and P2P models are licensable under the exchange and order-handling permissions — but transactions must run non-cash. A transition rule allows small cash operations (≈US $800 equivalent) only until 31 January 2027.

Already operating in Armenia?

Providers active before the regulations took effect have until 31 January 2027 to obtain a licence or wind down. If that’s you, the clock is already running.

A central-bank licence in a young framework is an early-mover asset: the requirements are real, and so is the credibility.

The contrast

Why not just license in the US?

The US route means FinCEN registration plus state-by-state money transmitter licences — six-figure budgets and 6–18 month reviews per state. Armenia gives you one regulator, one application and central-bank credibility for a fraction of that. See the US route or compare all three.

Honest fit

Is this the right fit?

Armenia works when

Your clients and partners are in the CIS region
You want a central-bank licence, not an offshore stamp
Your model is OTC, exchange or brokerage-style services
You can fund the regulatory capital tier for your activities

Look elsewhere when

Speed and minimal capital are decisive — see El Salvador
US market access is the point — see the US route
Your model depends on cash operations

FAQ

Armenia CASP — common questions

Is crypto licensing in Armenia already mandatory?

Yes. The Law on Crypto-Assets entered into force in July 2025, and the Central Bank’s implementing regulations took effect on 31 January 2026. New providers need a licence before starting; businesses that were already operating have a transition window until 31 January 2027.

How much capital does a CASP licence require?

It depends on your activity set: from about US $26,000 for advisory services, to roughly US $52,000 for order handling and transfers, around US $130,000 for dealing and custody, and about US $182,000 for operating a trading platform. The highest applicable tier governs, and the capital must be deposited in an Armenian bank.

How long does the Central Bank review take?

About 2–3 months for the licence application itself; 3–5 months end to end including incorporation, capitalisation and preparing the compliance file.

Can I run an OTC or P2P desk under this licence?

Yes — OTC and P2P models fit under the exchange and order-handling permissions. Note that transactions must be non-cash; a transitional allowance for small cash deals (≈US $800 equivalent) expires on 31 January 2027.

Is the Armenian licence recognised internationally?

It’s a young framework, but it comes from a central bank and mirrors the EU’s MiCA structure — which banks and counterparties read far better than an offshore registration. For CIS-facing businesses it’s often the most credible licence realistically within reach.

Next step

Get licensed in Armenia

Tell us your activity mix and we’ll map it to the right permission set and capital tier — before you commit a single dram.

Discuss your project