On 28 September 2026, Belarus’s High-Tech Park registered the country’s first two “crypto-banks” — a legal status that barely exists elsewhere. The headline invites two misreadings: that a crypto-bank is a crypto exchange dressed up as a bank, or a bank that has started holding crypto. In law it is neither.
It is a purpose-built hybrid — an HTP resident authorised to combine token activity with certain banking, payment and financial operations — created across 2026 by a dedicated decree and a layer of acts from the government, the National Bank and the HTP. For anyone advising in this space, the interesting part is not the novelty but the architecture: the status is authorised in two steps, not one, and it sits under a genuinely dual regime. HTP registration — the event everyone reported — supplies the digital-asset side; it does not by itself let a crypto-bank operate, because inclusion in the National Bank’s register is also required, which is why the two newly registered residents are not yet in business as crypto-banks. And the regime is supervised accordingly. This piece is what happened and what the new category means in law.
The HTP’s Supervisory Board, chaired by the Prime Minister, registered two residents in the status of crypto-bank — the first in Belarus — at its meeting on 28 September 2026. It follows a July 2026 decree on crypto-bank activity and a set of 2026 acts by the government, the National Bank and the HTP that built the framework over the preceding months — the requirements for the organisations, the list of permitted operations, and the accounting and reporting rules. The two organisations have not been named publicly; officials described them as established crypto-market players with practical experience. As reported by the state news agency, the HTP Secretariat called the step a significant, evolutionary one — bringing traditional finance and the crypto sphere closer together.
The analysis worth getting right is that this is a defined new category, not a relabelled old one. A Belarusian crypto-bank is neither a classic bank nor an ordinary crypto exchange: it is an HTP resident authorised to combine token (crypto) activity with certain banking, payment and other financial operations, under the HTP’s digital-asset regime. It can therefore do some of what a bank does and some of what a crypto platform does, within one regulated entity — which is precisely the bridge between traditional finance and crypto that the legislature set out to build. That hybrid character is deliberate, and it is what makes the status genuinely novel in legal terms: not an exchange calling itself a bank, nor a bank dabbling in crypto, but a distinct category constructed to sit between the two, with its own permitted scope and its own rules.
This is the structural point counsel most needs to get right. Authorisation is a two-stage licence, and HTP registration — the event of 28 September — is only the first stage. To operate as a crypto-bank, the organisation must also be included in the National Bank’s register. The HTP’s special regime supplies the right to work with digital assets; the National Bank’s registration adds the requirements that attach to ordinary banking and payment operations — and only with both in place is an organisation fully admitted to operate. So the two residents now hold the HTP status, but the National Bank step is outstanding, and until it is completed they cannot do business as crypto-banks. For advisers and counterparties, the practical consequence is that “registered as a crypto-bank” is not the same as “licensed to operate as one” — the second stage is the one that matters for actually transacting.
The compliance architecture is substantial, as befits an entity that straddles banking and crypto. Supervision is dual — the HTP and the National Bank both have a role — and, notably, while a crypto-bank’s data is protected as bank secrecy, the HTP Secretariat is entitled to obtain information on crypto-accounts and token-deposits, so confidentiality coexists with oversight rather than displacing it. A crypto-bank must warn clients about the risks of cryptocurrencies and their volatility. And it carries the obligations of a regulated financial business — requirements on the organisation itself, a defined list of permitted operations, accounting and reporting duties, and anti-money-laundering compliance. None of this is a light-touch arrangement: the status comes with continuing obligations and genuine supervision, which is what one would expect of a licence permitting an entity to handle both crypto and money, and it is where the real work of qualifying and operating will lie.
Read through an advisory lens, the development has three audiences. For a prospective crypto-bank, it is a real but demanding route — aimed at serious operators, requiring both licensing steps and a substantial compliance build, much as HTP residency itself does, but with the banking layer on top. For the counterparties and clients of a crypto-bank, the status shapes what dealing with one involves: bank-secrecy protection, dual supervision, and the mandatory risk disclosures that come with it. And for the wider market, it is a signal of how far the HTP’s digital-asset regime now reaches — beyond mining and exchanges, which the HTP already accommodates, into a banking-adjacent category. Each of those audiences has a different set of questions, but all of them turn on the same framework — the two-step licence and the dual-supervision rules — which is why getting the legal picture right at the outset matters.
Two things belong on any careful read. The status is AML-bound and dually supervised — a regulated financial status, not a loophole — and, like any Belarus-linked financial business, it sits within the current sanctions and banking environment, which must be navigated properly; it is a domestic regulatory development, not a vehicle for moving sanctioned money, and should not be treated as one. And, because the regime is new, it leaves open questions: the detailed requirements are still settling, the National Bank step is untested in practice, and how supervision will operate day to day remains to be seen. For anyone weighing it, that argues for assessing eligibility carefully, planning for both the HTP and National Bank stages, and taking advice as the framework develops — and for treating today’s position as a starting point, not a settled rulebook. For the corporate and regulatory questions a crypto-bank raises, that is exactly where specialist input earns its place.
A new hybrid legal category — authorised in two steps and dually supervised.
| Aspect | Detail |
|---|---|
| What it is | A hybrid legal category — an HTP resident combining token (crypto) activity with certain banking, payment and financial operations |
| First registered | Two HTP residents, 28 September 2026 (names not disclosed) |
| Enabled by | A July 2026 decree, plus 2026 acts of the government, the National Bank and the HTP |
| Authorisation | Two steps: HTP registration + inclusion in the National Bank’s register |
| Can it operate yet? | Not until the National Bank step is completed |
| Supervision | Dual — the HTP and the National Bank; the HTP can access crypto-account data |
| Confidentiality | Protected as bank secrecy, with HTP oversight |
| Obligations | Risk/volatility warnings, defined permitted operations, reporting, and AML compliance |
*As of the registration on 28 September 2026; the regime is new and developing, so confirm the current rules and status before acting.
A hybrid legal status for an HTP resident, authorised to combine token (crypto) activity with certain banking, payment and financial operations under the HTP’s digital-asset regime. It is not a classic bank and not an ordinary crypto exchange — it is a distinct, defined category constructed to sit between the two, with its own permitted scope and its own rules, intended to bridge traditional finance and crypto.
In law, neither — that is the point. A crypto-bank can carry out some banking, payment and financial operations and some token activity, within one regulated entity. The name misleads in both directions; it is best understood as a deliberately constructed hybrid, a new category rather than a rebranded exchange or a crypto-curious bank.
A two-stage licence: HTP registration (which supplies the digital-asset side) plus inclusion in the National Bank’s register (which adds the banking and payment requirements). Only with both in place is a crypto-bank fully admitted to operate. HTP registration alone — the 28 September event — is the first stage, not authorisation to transact.
Not yet as crypto-banks. The two residents hold the HTP status, but the National Bank step is outstanding, and until it is completed they cannot do business as crypto-banks. So “registered” is not the same as “licensed to operate” — the National Bank stage is the one that matters for actually transacting.
Both the HTP and the National Bank — dual supervision. A crypto-bank’s data is protected as bank secrecy, but the HTP Secretariat is entitled to obtain information on crypto-accounts and token-deposits, so confidentiality coexists with oversight. It is a supervised, accountable status, not a light-touch one.
Requirements on the organisation itself, a defined list of permitted operations, accounting and reporting duties, mandatory client warnings about crypto risk and volatility, and anti-money-laundering compliance. In short, the continuing obligations of a regulated financial business handling both crypto and money — ongoing, not a one-off, and where much of the real compliance work will lie.
For a counterparty or client, dealing with a crypto-bank means dealing with a dually-supervised entity whose data is protected as bank secrecy (with HTP oversight) and which must make the mandatory risk disclosures. The status shapes the legal relationship — so understanding it matters for anyone contracting with, or placing assets with, a crypto-bank, not only for the crypto-bank itself.
No. A crypto-bank is a regulated, AML-bound status under dual supervision, operating within Belarus’s wider compliance and sanctions environment, which must be navigated properly. It is a domestic regulatory development to bridge finance and crypto — not a vehicle for moving sanctioned money, and it should not be treated as one.
Belarus has created, and now populated, a new legal category between banking and crypto — a two-stage licence under dual HTP and National Bank supervision, with bank-secrecy-with-oversight and anti-money-laundering obligations. It is a genuine development for serious operators, but the compliance architecture, not the headline, is what matters, and parts of the regime are still settling. The two residents hold the HTP status; the National Bank step, and how the framework beds in, are what to watch next.
If the crypto-bank status is relevant to your plans — whether you are considering the licence, advising a prospective crypto-bank, or dealing with one — tell us the situation, and we will advise on where the regime stands and what it requires. Get in touch, and see our work on the Hi-Tech Park regime it sits within.
