Registration of Crypto Brokers

The cryptocurrency market in Belarus continues to evolve, with more and more companies considering opportunities in this sector. However, the activities of crypto brokers are subject to regulation: without completing the official registration procedure and obtaining the status of a High-Tech Park (HTP) resident, it is impossible to run such a business legally.

The registration of crypto brokers in Belarus has its own unique challenges. Unlike many countries where cryptocurrency activity is unregulated or restricted, our jurisdiction has created a legal framework that allows for legal work with digital assets. The procedures and conditions for the operation of crypto exchanges, crypto brokers, and other market participants are established.

Companies planning to provide cryptocurrency brokerage services must consider a number of requirements: establishing a legal entity as a Belarusian resident, obtaining HTP resident status, meeting capital and reserve requirements, establishing internal controls, and adhering to anti-money laundering regulations. The process of registering a crypto broker requires thorough preparation of documents and a clear understanding of the legal nuances, making it essential to approach this step with the utmost responsibility.

This article explores how the registration of crypto brokers in Belarus is carried out, what requirements companies must meet, and what to pay attention to when preparing to obtain the status.

Who Are Crypto Brokers?

Crypto brokers are professional intermediaries who provide users with access to transactions with cryptocurrencies. Unlike crypto exchanges, where transactions are made directly between buyers and sellers, the broker acts as a link and offers clients a user-friendly interface, additional services and guaranteed execution of transactions.

Essentially, a crypto broker operates on the same principle as a traditional financial broker: it helps buy or sell assets, but instead of stocks or currencies, it deals with digital tokens and cryptocurrency.

Key functions of crypto brokers include:

• Providing a platform for buying and selling cryptocurrencies
• Safekeeping client funds and ensuring their security
• Simplifying access to international digital asset markets
• Consulting and assisting clients in choosing investment tools
• Ensuring transparency and compliance with legal requirements

How Crypto Brokers Differ from Crypto Exchanges

An exchange is a platform where users trade directly with each other, and prices are determined by supply and demand. A broker, on the other hand, provides liquidity and acts as the counterparty to the transaction, making the process faster and more reliable for the client.

In Belarus, crypto brokerage is regulated by Decree No. 8 “On the Development of the Digital Economy” and is only possible with official registration. This status gives businesses the right to operate legally, benefit from HTP tax incentives, and build greater trust with clients.

Types of Activities of Crypto Brokers

To operate as a crypto broker in Belarus, a company must obtain the status of an HTP resident. This status is granted exclusively to legal entities registered in the country. It opens significant opportunities for businesses but also requires compliance with a number of obligations.

HTP residents are allowed to conduct token transactions on behalf of and in the interests of their clients if their business model includes one of the activities specified in the HTP Regulations, such as:

• Other types of activities involving tokens, including those with features of professional and exchange activities on the securities market, investment fund management, or securitization
• Issuance, placement, and circulation of own tokens

Requirements for Crypto Brokers

In addition to obtaining HTP residency status, a crypto broker must meet a range of strict qualification, reputational, financial, and technical requirements.

Charter Capital

The minimum charter capital for a crypto broker company is 500,000 Belarusian rubles (approximately USD 165,000). These funds must be deposited into the company’s bank account before submitting documents to the HTP Administration. Subsequently, the funds can be used for the company’s business operations.

Staff and Key Specialists

The company’s staff must include the following positions (some may be outsourced):

• Director
• Chief Accountant
• Risk Manager
• AML/CFT Specialist (Anti-Money Laundering / Countering Financing of Terrorism)
• HTP Compliance Officer

Additionally, employees who execute token transactions and interact with clients must meet established criteria:

• Higher education degree
• First-category securities market qualification certificate
• Verified experience in relevant positions (Director, Chief Accountant, AML/CFT Specialist)

Reputational Requirements for Personnel

Key employees must have an impeccable professional reputation, including:

• No criminal record for property-related crimes
• No dismissals for discrediting reasons
• No ongoing criminal proceedings

Reputational Requirements for Founders and Beneficiaries

Specific requirements also apply to the company’s owners:

• No criminal record for economic crimes
• No outstanding tax or other government payments
• No involvement in the legalization of criminal income or its financing
• No history of bankruptcy (either completed or ongoing)

Use of Specialized Software

A crypto broker must use software for monitoring financial transactions and identifying potentially suspicious activities. These systems must comply with international compliance standards and come only from certified providers. Currently acceptable solutions include software developed by Elliptic (UK), Chainalysis (USA), Coinfirm (UK), Neutrino (Italy), and Crystal Blockchain B.V. (Netherlands).

Internal Documentation

A crypto broker must develop and approve a package of mandatory internal documents that regulate:

• Procedures for entering into contracts with clients and crypto platform operators
• Internal security measures
• Transaction monitoring procedures
• Conditions for token issuance and sale
• Other matters related to organizational operations and legal compliance

Big 4 Financial Audit

One of the mandatory requirements is an independent financial audit to verify compliance with applicable regulations. The audit must be conducted by a Big 4 accounting firm (PricewaterhouseCoopers, KPMG, Deloitte Touche Tohmatsu, Ernst & Young) or by a firm formerly part of this group and operating in the Belarusian market.

Technical Audit

In addition to financial verification, a crypto broker must submit its online platform for a technical audit by a specialized third-party company. The audit aims to confirm that the system meets all current security and reliability requirements.

Key Responsibilities of a Crypto Broker

For legal and secure operations, a crypto broker must comply with a set of established requirements aimed at protecting clients’ interests and ensuring transparency. Specifically, the broker must:

• Maintain separate accounting for its own funds and client assets, including funds held with crypto platform operators.
• Provide clients with reports on order execution and contract terms within the deadlines agreed upon.
• Record all token transactions executed on behalf of clients and create daily backups of this information.
• Record client communications (including video calls) and retain them along with all interaction data for at least five years.

Stages of Crypto Broker Registration

Registering a crypto broker in Belarus is a complex process requiring careful preparation and strict compliance with formal requirements. It consists of several key stages:

1. Preparation of Founding Documents

At the initial stage, a legal entity is established in Belarus and a package of founding documents is prepared. It is important to explicitly include the ability to conduct token-related activities in the charter and ensure compliance with High-Tech Park (HTP) requirements. At this stage, the minimum charter capital (BYN 500,000) must also be deposited into the company account.

2. Application for HTP Residency

The next step is to prepare and submit a package of documents to the HTP Supervisory Board Secretariat. It includes a business project, information about the founders, evidence of financial viability, a description of the IT project and the internal structure of the company.

3. Compliance Verification

After submitting the application, the HTP Supervisory Board Secretariat conducts a detailed review: assessing the business project’s compliance with legislation, analyzing the financial indicators, the business reputation of the founders and key employees, the availability of required personnel, and the use of the required transaction control software. A financial and technical audit may also be required at this stage.

4. Obtaining Status and Starting Operations

If the company meets all requirements, it receives HTP resident status and the right to officially provide crypto brokerage services. After this, the organization is required to register internal documents, set up an accounting and reporting system, and enter into agreements with clients and crypto platform operators. Only after completing these steps can it fully commence operations.

Advantages of Registering a Crypto Broker in Belarus

Belarus is one of the few countries where cryptocurrency operations are officially regulated at the state level, creating favorable conditions for business and attracting companies working with digital assets.

Transparent Legal Framework

Crypto brokerage activities are regulated under Decree No. 8 “On the Development of the Digital Economy.” This provides entrepreneurs with clear rules and reduces legal risks associated with uncertain legislation, as is the case in many other countries.

HTP Tax Incentives

HTP residents are exempt from income tax, VAT, and a number of other mandatory payments. This allows crypto brokers to invest more in development and attract clients through competitive conditions.

International Recognition

Belarus is among the jurisdictions actively developing the digital economy. Registering a cryptobroker in the HTP increases the trust of investors and clients, as the company’s activities are officially licensed and subject to strict oversight.

Ability to Serve International Clients

HTP residency allows brokers to provide services not only domestically but also to clients abroad, opening access to the international digital asset market and expanding business prospects.

Reputational Benefits

A crypto broker registered in Belarus demonstrates to partners and clients a serious approach to business, adherence to international AML/CFT standards, and a high level of transparency. This is particularly important for companies working with institutional clients.

Practical Recommendations

Registering a crypto broker in Belarus requires not only legal knowledge but also a strategic approach. Mistakes at the preparatory stage can lead to refusal of HTP residency or delays in the process.

Preparing Documents for Submission

• Prepare a complete package of founding documents in advance.
• Deposit the charter capital of BYN 500,000 before submitting the application.
• Develop a detailed business plan outlining services, technical infrastructure, and projected financials.
• Ensure key personnel qualifications are documented (degrees, certificates, work experience).

Key Considerations for Business Model Design

• Comply with HTP requirements for token-related activities.
• Define procedures for accounting for client funds and company assets.
• Implement certified transaction monitoring software.
• Develop internal policies for security, client interactions, and cooperation with crypto platform operators.

When to Involve a Lawyer or Consultant

Professional assistance is recommended at the application preparation stage. Lawyers or consulting firms can:

• Structure the business correctly and choose the optimal model.
• Draft the charter and internal policies in compliance with HTP requirements.
• Verify the company meets qualification and reputational criteria.
• Support document submission and interactions with the HTP Administration.

Comprehensive support minimizes the risk of refusal and accelerates the process of obtaining crypto broker status.

Conclusion

Registering a crypto broker in Belarus is a complex, multi-stage process that involves legal verification, financial and technical compliance, and mandatory acquisition of High-Tech Park residency. Successful launch requires not only adherence to established standards but also a business model aligned with client interests and regulatory requirements.

Our EOR team is ready to provide end-to-end support for crypto broker registration — from document preparation and internal policy development to interaction with HTP and business consulting. With our assistance, you will mitigate risks, shorten registration timelines, and establish a solid legal foundation for operating in Belarus’ cryptocurrency market.