The newly established Crypto Business Union NGO has voiced concern over a draft law on crypto regulation that is set to be reviewed in Armenia’s parliament on December 16, following government approval on December 11.
In an open letter addressed to Prime Minister Nikol Pashinyan, Central Bank Governor Martin Galstyan, High-Tech Minister Mkhitar Hayrapetyan, Economy Minister Gevorg Papoyan, and relevant MPs, the union states that the bill does not solve core industry issues and imposes disproportionate, discriminatory, and economically unjustified restrictions.
The concern stems from a provision banning cash-based crypto transactions starting January 1, 2026, a measure initially passed in 2024 at the Interior Ministry’s suggestion to combat financial crime.
Crypto businesses argue that cash remains essential due to the banking system’s inefficiency in servicing the sector, the nature of international transactions, and the demands of tourism-related crypto usage.
Although the National Assembly postponed the ban by one year after sector appeals, the Central Bank now considers the matter closed, proposing a temporary workaround: companies that operated before July 4, 2025, may continue limited cash transactions for one year, capped at AMD 300,000 per transaction, under full Central Bank oversight and strict AML/KYC protocols, including collection of clients’ ID and residential address.
The union argues this creates unfair restrictions not applied to banks or currency exchange outlets, which either lack such transaction limits or have more lenient identity verification rules for similar cash amounts. They note that similar limits do not exist in Georgia, Russia, or the UAE, potentially driving the market abroad and depriving Armenia of billions in revenue and taxes.
With an estimated $9 billion in annual crypto turnover and 450,000 users in Armenia, the union warns that by 2027, crypto businesses may be forced to cease local operations entirely under current regulations.
The union proposes two key changes:
- Remove the AMD 300,000 cap on crypto transactions, since licensed crypto firms will operate under Central Bank supervision and comply with AML/KYC standards.
- Abolish the time restriction, allowing cash transactions only until the end of 2026. Allow both cash and non-cash transactions on an ongoing basis.
They emphasize the need for open dialogue with authorities and readiness to engage in lawmaking, public consultations, and education initiatives.
