Pembentukan Perusahaan Cryptocurrency & Blockchain dan Lisensi CASP di Armenia

Armenia introduced mandatory licensing for crypto-asset service providers (CASPs) through the Central Bank of Armenia, effective January 31, 2026. For international crypto entrepreneurs, fund managers, and blockchain companies evaluating Armenia as a jurisdiction, this guide covers the full end-to-end process: LLC formation for crypto entities, CASP licence application, capital requirements, banking for licensed businesses, tax treatment, and how Armenia compares to competing jurisdictions.

Whether you are a UAE-based crypto fund considering an Armenian subsidiary, a developer wanting to formalize an exchange or custodial service, or a fintech team exploring cost-effective licensing jurisdictions, this guide gives you the practitioner-level detail you need to move forward.

Why Armenia for crypto and blockchain companies

Armenia’s appeal for crypto businesses rests on several converging factors. The country now has a clear regulatory framework under the Law on Crypto-Assets, with the Central Bank serving as the single licensing authority. This regulatory clarity, combined with low formation costs and competitive tax rates, positions Armenia as a practical alternative to more expensive jurisdictions.

Key advantages include free LLC registration with the State Register, processing in as few as two business days, 100% foreign ownership with no local partner requirement, an 18% corporate income tax rate, a 5% dividend withholding tax for non-residents, potential eligibility for Armenia’s high-tech sector incentives (60% income tax reimbursement on new employee salaries for qualifying entities with 90% or more high-tech turnover), and access to nearly 50 double tax treaties including with the UAE, EU member states, Russia, and India.

Armenia also offers a growing tech ecosystem, low operational costs (office space, salaries, and professional services are a fraction of what you would pay in the UAE, EU, or Singapore), and a strategic time zone bridging Europe and Asia.

Step 1 — LLC registration for crypto entities

Only Armenian-registered LLCs (limited liability companies) or JSCs (joint-stock companies) are eligible for a CASP licence. For most crypto businesses, the LLC is the standard and most practical entity type. Here is the formation process:

1. Charter and founding decision. Draft the company charter and founding decision. The charter should describe your intended business activities broadly (IT services, fintech, digital asset services). While no crypto-specific wording is legally mandated, a clear description of your intended crypto activities helps with the subsequent CASP application and bank account opening.

2. Document preparation. For foreign founders, you will need your passport translated into Armenian and notarized, along with a power of attorney if you are not filing in person. An e-signature option is available for online filing.

3. State registration. File with the State Register of Legal Entities. Registration is free of charge. Processing takes 2-7 calendar days, after which you receive a state registration certificate and tax identification number (TIN).

4. Post-registration steps. Register with the State Revenue Committee for tax purposes, set up employer registration if hiring staff, and open a corporate bank account. The bank account is a prerequisite for your CASP licence application, as capital must be deposited in an Armenian bank.

A foreign national can serve as both the sole founder and sole director. There is no minimum share capital requirement for LLCs in Armenia (the CBA sets separate capital requirements for the CASP licence itself). A registered office address is required; virtual offices are commonly used for LLCs, though note that CASP licensees must maintain physical premises that meet CBA criteria.

For a detailed walkthrough of the LLC formation process, see our pendaftaran bisnis di Armenia panduan.

Step 2 — CASP licence application with the Central Bank

Who needs a CASP licence

Under Armenian law, any entity providing crypto-asset services in or from Armenia must hold a CASP licence from the Central Bank. The law defines 10 categories of regulated crypto-asset services: operating a trading platform, custody and administration of crypto-assets, buying or selling crypto-assets on the provider’s own behalf, buying or selling crypto-assets on behalf of clients, transmitting orders related to crypto-assets, placement of crypto-assets, crypto-asset portfolio management, providing advice on crypto-assets, transfer of crypto-assets, and issuance of asset-referenced tokens. A single licence can cover one or more (or all) of these activity types. Additional services can be added later through a supplementary application with an amended charter and business plan.

Application dossier

The CASP licence application requires a comprehensive dossier submitted to the CBA. Based on the requirements under Armenian law, the application package includes: the formal application, entity details, a three-year business plan, the approved company charter, trade name registration, draft internal rules and compliance policies, documentation of executive appointments, manager registration documentation, qualifying holding approval documents (required for shareholders holding 10% or more), proof of minimum capital deposited in a non-affiliated Armenian bank, a premises compliance statement demonstrating physical office meeting CBA criteria, information security compliance documentation, state duty payment receipt, and any additional documents prescribed by the CBA.

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CBA Regulation 7/02 (Resolution 228-N) sets the following minimum capital tiers based on the type of crypto-asset service:

Capital must be deposited in a non-affiliated Armenian bank before the licence application is submitted. Where a CASP provides multiple service types, the highest applicable tier applies. Your V&P adviser can confirm the exact capital tier for your specific service mix.

Garis waktu dan proses

The CBA has not published a statutory review deadline for CASP applications. Based on analogous CBA licensing processes (such as payment organization licensing, which carries a two-month review period from receipt of a complete application), practitioners estimate the CASP review at approximately two to three months. The overall timeline from LLC formation through CASP licence issuance is estimated at three to five months, depending on the completeness of your application and the speed of document preparation.

Existing crypto-asset service providers that were operating before the regulations took effect have until January 31, 2027 to complete the licensing process under the transitional provisions.

Step 3 — Banking for licensed crypto businesses

Banking is one of the most critical practical considerations for crypto businesses in Armenia. Since January 31, 2026, crypto-asset service providers must be registered and licensed by the Central Bank. Unlicensed crypto businesses face significant difficulty opening or maintaining bank accounts, as banks screen crypto businesses as part of their AML/KYC procedures and may refuse account opening or close existing accounts for unlicensed providers.

Armenia has 17 banks supervised by the Central Bank. No bank has publicly positioned itself as specifically crypto-friendly, but several are known to work with licensed entities on a case-by-case basis following their internal risk assessment. The account opening process for a crypto company involves a preliminary assessment, document submission (including CASP licence evidence, shareholder and beneficial owner disclosure, AML/CFT policies, risk management documentation, and capital documentation), AML review, and risk committee approval.

Crypto companies can open accounts at multiple banks, and there is no restriction on this. For international payments, Payoneer works well with Armenian companies. Stripe is not available in Armenia. Crypto-asset holdings can be carried on the company’s balance sheet (typically classified as intangible assets under IAS 38 or as inventory under IAS 2, with fair value measurement per IFRS 13), and client assets must be segregated from the company’s own assets. Note that under the Crypto-Assets Law, commercial banks cannot provide crypto-asset services directly — they must establish and separately license an independent legal entity for this purpose.

The practical takeaway: obtain your CASP licence before approaching banks, and work with an adviser who understands which banks have experience with licensed crypto entities. For more on the Armenian banking landscape, see our perbankan di Armenia panduan.

Ongoing compliance and reporting

Once licensed, CASPs must maintain ongoing compliance with CBA regulations and Armenian AML/CFT law. Key obligations include: implementing and maintaining AML/KYC controls for all customers, monitoring transactions and filing suspicious activity reports, record-keeping of all transactions and customer identification data, maintaining minimum capital adequacy at all times, risk management and governance policies, and periodic reporting to the CBA.

Armenia participates in CRS/AEOI (automatic exchange of financial information) since 2025 with over 47 partner jurisdictions, and maintains FATCA compliance with the United States. While CASPs have not yet been explicitly classified as reporting financial institutions under CRS, entities meeting custodial or investment entity criteria may qualify. Armenia has also committed to implementing the OECD’s Crypto-Asset Reporting Framework (CARF) by 2027, which will introduce crypto-specific cross-border reporting obligations.

Tax treatment of cryptocurrency business income

Armenia taxes crypto business income under its existing corporate tax framework. The standard corporate income tax (CIT) rate is 18%, applied to all business profits including income from trading, exchange fees, custody fees, and other crypto-asset services. There is no separate capital gains regime for companies; all income is taxed as ordinary business profit.

Dividends distributed from an Armenian crypto company to non-resident shareholders are subject to a 5% withholding tax, which is the final Armenian tax on those distributions. This rate may be reduced further under Armenia’s network of nearly 50 double tax treaties, including treaties with UAE, EU member states, Russia, and India (there is no treaty with the United States).

The alienation (sale or disposal) of crypto-assets is VAT-exempt under Tax Code Article 64. This means that fiat-to-crypto transactions, crypto-to-crypto swaps, and crypto disposals do not attract VAT. However, service fees charged by CASPs — including exchange commissions, custody fees, and brokerage fees — are standard taxable services subject to 20% VAT.

Transfer pricing rules apply to transactions between related entities, following OECD-aligned principles. The reporting threshold is AMD 600 million (~USD 1.5 million), with three-tier documentation requirements in effect since 2025.

For individuals, Armenia offers highly favourable crypto tax treatment under Tax Code amendments HO-175-N: non-entrepreneurial individuals pay 0% capital gains tax on standard crypto-asset sales, while income from mining, staking rewards, and NFT disposals is taxed at just 1% (Tax Code Article 150, Part 9.1). If individual trading activity crosses into business-level frequency, the standard 18% CIT applies. Note that crypto losses cannot be deducted against other business income (Article 113), and licensed CASPs are barred from the simplified turnover tax and micro-enterprise regimes. Crypto-assets cannot be used as a means of payment in Armenia — a prohibition codified in the Civil Code, with the sole exception being e-money tokens under the Crypto-Assets Law.

For detailed tax guidance, see our pajak di Armenia panduan.

Armenia vs. competing jurisdictions

For founders evaluating where to incorporate and license their crypto business, here is how Armenia compares to key alternatives:

Armenia’s key advantages: free LLC registration, fast licensing timeline, low operational costs, potential high-tech tax incentives, no currency controls, and a growing regulatory framework. Pertimbangan utama: no EU passporting (MiCA authorization requires an EU entity), a cautious banking sector, a new and maturing regulatory framework, and limited international recognition of the Armenian CASP licence at this stage.

For many crypto businesses, Armenia works well as a cost-effective operational and licensing base, particularly when combined with an EU entity for passporting if EU market access is needed.

V&P’s CASP licensing service package

Vardanyan & Partners handles the end-to-end process for crypto businesses establishing in Armenia. Our CASP licensing service covers LLC registration (entity formation, charter drafting, State Register filing), CASP licence preparation and application (dossier assembly, CBA liaison, compliance policy drafting), banking introduction (connecting you with banks experienced in working with licensed crypto entities), and ongoing compliance advisory (AML/KYC framework setup, regulatory reporting guidance, tax structuring).

Our team has 14+ years of experience in Armenian corporate and regulatory law, having handled 1,500+ cases across 97 nationalities. We work directly with the CBA on licensing matters and understand the practical requirements beyond what is written in the regulations.

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