On January 16, 2026, Belarusian President Alexander Lukashenko signed Decree No. 19, which for the first time gave the green light at the national level for so-called "cryptocurrency banks," incorporating this new entity into the existing financial licensing system. According to the decree's framework, cryptocurrency banks must operate based on the specific platform of the Belarus High-Tech Park (HTP) and fully apply the country's regulatory rules for non-bank credit financial institutions, undertaking token-related businesses and quasi-traditional financial services under the same regulatory umbrella. The core conflict arising from this is also becoming apparent: when traditional financial regulatory logic overlaps with the high volatility and high innovation of crypto assets within the same licensing system, how to delineate regulatory boundaries and allocate responsibilities will become key in subsequent negotiations. For Belarus, this could be an opportunity to achieve a "shortcut" through the high-tech park and new financial infrastructure, or it could be a high-leverage gamble betting on regulatory risks and national reputation.
From Digital Economy Decree to Cryptocurrency Bank
Returning to the timeline, this decree from Belarus is not starting from scratch. As early as 2017, Belarus passed the "Digital Economy Development Decree," clearly positioning the High-Tech Park (HTP) as a core testing ground for digital economy and blockchain businesses. Since then, the HTP has been officially designated as the main carrier for financial information technology and crypto-related businesses. This decree provided a special environment for blockchain development, related software exports, and pilot crypto businesses in terms of taxation and regulation, gradually establishing the park as an "innovation enclave" within the national economic structure. Subsequently, the HTP has successively legalized ICOs, token issuance, and smart contract operations, allowing project teams to conduct financing and product testing within the park's framework, laying the institutional foundation for today's regulatory upgrade and accumulating nearly a decade of regulatory and technical experience in practice.
By juxtaposing the 2026 Decree No. 19 with the 2017 Digital Economy Decree, we can clearly see the deepening changes in regulatory logic. In the previous phase, the policy focus was on "allowing projects": permitting teams to issue tokens, deploy smart contracts, and explore new business models within the park; while this upgrade attempts to bundle tokens with quasi-banking services at the level of "allowing banks," elevating past experiments that were more project and technology-oriented to institutional innovations involving financial infrastructure levels such as deposits, loans, custody, and settlement. This leap from project level to banking level reflects Belarus's clearer national strategic intent: on one hand, to consolidate its differentiated advantage in financial information technology through a continuous regulatory path, attempting to find a new position in the global financial system; on the other hand, it also reflects a strong mindset to seize future discourse power through institutional innovation against the backdrop of intensified international competition and restricted traditional financial channels.
What Does a Cryptocurrency Bank Look Like: "Non-Bank Laboratory" in the Park
From the information disclosed in the decree text, the outline of cryptocurrency banks is first delineated by two hard thresholds. The first threshold is the identity threshold: institutions must be resident enterprises of the Belarus High-Tech Park, meaning they need to have a physical presence in the park and accept the existing governance, taxation, and compliance arrangements of the park. The second threshold is the regulatory attribute: these institutions will be legally regarded as non-bank credit financial institutions and must fully apply the existing regulatory rules under this path, which naturally incorporates them into the existing regulatory framework of the country's non-bank financial system.
The so-called regulatory framework for non-bank credit financial institutions essentially requires these institutions to align with traditional financial standards in areas such as anti-money laundering, capital constraints, and risk control. By directly linking cryptocurrency banks to this framework, it means that regardless of how their business combines with digital tokens, they must comply with a complete set of traditional financial logic constraints, including customer identity verification, suspicious transaction reporting, capital adequacy, and internal risk control. Meanwhile, the official statement that "cryptocurrency banks can conduct traditional financial businesses in conjunction with digital tokens" outlines the possible boundaries of their business landscape: under compliance conditions, credit businesses based on token pledges or collateral, custody and settlement services targeting tokens, and cross-border settlement and payment services provided in the form of digital accounts could all potentially be organized and offered in a bank-like manner under this new institutional form. It is important to emphasize that specific compliance details have not yet been published, and there are no clear answers in the public information regarding which businesses will be prioritized or how to quantify risk control parameters; at the same time, the list of cryptocurrency banks that have applied for or been approved is completely absent, leaving the regulatory pace and ecological scale at the level of expectations, requiring external observers to remain sufficiently cautious when interpreting and imagining these business scenarios.
Consolidating Competitive Advantage or All-In Gamble
In external statements, Belarus has clearly positioned this decree as an important step to "consolidate Belarus's competitive advantage in financial information technology and crypto assets," providing direct clues to understanding its policy motivations. In a broader context, Belarus has long been in a complex geopolitical and financial sanctions environment, where the availability and stability of traditional financial channels are not entirely under its control. Therefore, developing a controllable crypto financial infrastructure and building a relatively independent payment and financing network has become a realistic, even forced, strategic choice. Countries that find it difficult to gain sufficient voice in the traditional system hope to leverage new technologies and new systems to bypass some existing intermediaries and central nodes, thereby reducing dependence on a single financial system; this impulse has not been uncommon in recent years' international landscape.
However, Belarus has not chosen to fully open up nationwide but has strictly limited cryptocurrency banks to the internal environment of the High-Tech Park. This design reflects a dual consideration of "regulatory sandbox" and "reputation firewall." On one hand, the park is originally a gathering place for blockchain and digital businesses, where regulatory agencies have accumulated considerable technical and compliance experience, making it beneficial to include cryptocurrency banks for concentrated risk observation and rapid rule iteration; on the other hand, locking high-sensitivity innovative financial businesses within specific geographical and institutional boundaries also reserves buffer space for the country's overall reputation, theoretically making it easier to isolate from the national financial system in the event of a risk incident. It is worth noting that all interpretations of the policy can only be based on publicly available texts and limited statements. Specific remarks made by Lukashenko in the past regarding the crypto field and rumors about blocking exchanges have been explicitly marked in briefings as prohibited from being trusted or pending verification. Therefore, when analyzing this policy, one can only cautiously revolve around the public decree and cannot piece together unverified narratives to avoid misleading interpretations.
Counter-Cyclical Testing Ground Amid Global VC Retreat
Looking at the global perspective, Belarus's move is occurring in a large cycle that is not "favorable." According to briefing data, global cryptocurrency VC transaction volume decreased by about 60% in 2025, indicating that the institutional funds that have driven the industry's explosive growth in recent years are significantly retreating. Meanwhile, the focus of global investment is clearly shifting towards AI + crypto, RWA, and other tracks that are closer to real assets or productivity narratives, making it increasingly difficult for projects relying solely on "on-chain stories" to gain sufficient capital resonance. In this context, Belarus has chosen to increase its institutional bets on crypto financial infrastructure, attempting to raise its stakes during a phase of reevaluation of crypto narratives, which inevitably forms a strong contrast with mainstream market trends.
However, from the development logic of the High-Tech Park itself, the VC retreat is not necessarily bad news. It is precisely in a period where funding is becoming more rational that those projects and fintech teams that genuinely need clear regulatory identities and seek long-term sustainable development are more motivated to find relatively clear and predictable institutional environments. By attaching a clearer "financial institution identity" to crypto entities within the High-Tech Park, Belarus has, to some extent, reduced regulatory uncertainty, providing a relatively clear institutional path for teams wishing to operate outside the gray area. From this perspective, Belarus clearly hopes to shape another image of a crypto financial safe haven, with institutional supply as a selling point, beyond the Middle East and some Asian markets. However, whether this goal can be achieved depends on how future details balance innovation space and compliance burdens, as well as whether international capital is willing to deploy resources long-term in a jurisdiction with not low geopolitical risks; these questions currently have no standard answers.
Risk Puzzle Under the Overlap of Traditional Finance and Token Economy
In Decree No. 19, the statement that "cryptocurrency banks can conduct traditional financial businesses in conjunction with digital tokens" reveals a deeper structural change: traditional financial logic and token economy are beginning to overlap within the same institution and the same balance sheet. Imagine a typical scenario where a crypto bank allows customers to use tokens as collateral to obtain credit limits, or allows institutional clients to use token assets as collateral for financing; the severe price fluctuations of tokens can quickly transmit through leverage and collateral chains to the entire credit system. For example, funds recorded and settled in token form, once connected with cross-border payment and settlement networks, will pose new challenges to existing capital flow monitoring and foreign exchange management. These scenarios are not simply "on-chain versions of old businesses," but rather present unprecedented challenges to traditional financial risk control parameters based on high-frequency token volatility and around-the-clock trading.
From a regulatory perspective, incorporating crypto assets into the regulatory framework for non-bank credit financial institutions is a "stitched" institutional attempt. On one hand, it provides regulators with a ready-made toolbox, allowing them to use mature indicators such as anti-money laundering, customer due diligence, capital adequacy, and risk weights to constrain new types of businesses; on the other hand, this stitching also naturally creates space for regulatory arbitrage: institutions can design complex structures in the gaps between the new and old rules that do not fully match, in order to evade some capital requirements or information disclosure obligations, making it difficult for regulators to timely identify hidden risks. In terms of cross-border capital flows and anti-money laundering, the regulatory model concentrated in the High-Tech Park can form certain advantages in terms of technology and human resources, facilitating unified monitoring of token transactions and cross-border flows. However, when these flows intersect with the regulatory boundaries of other jurisdictions, how to reach consensus on information sharing, law enforcement cooperation, and compliance standards may also become potential friction points.
More critically, when token prices fluctuate sharply, on-chain protocols experience security incidents, or individual crypto banks encounter credit events, the market will quickly raise another question: will the state back this "park experiment"? Once regulation explicitly or implicitly provides some degree of guarantee, it will invisibly strengthen market expectations for "state endorsement," pushing risk appetite to rise and ultimately amplifying systemic risks; conversely, if responsibility is chosen to be cut during a crisis, clearly stating that no rescue will be provided, it may also impact the country's financial reputation in the short term. This dilemma is a reality that any country attempting to deeply integrate tokens with traditional finance must confront.
Can a National Cryptocurrency Bank Sample Leverage a Larger Landscape?
In summary of the above timeline and institutional arrangements, it is clear that Belarus's path choice is relatively straightforward: first, through the 2017 Digital Economy Decree, establish a project testing ground for blockchain and token businesses within the High-Tech Park, and then use the 2026 Decree No. 19 as a fulcrum to elevate the experiment from the "project level" to the "banking level," attempting to transform tokens from fundraising and technology carriers into a part of financial infrastructure. This evolution from shallow to deep, from point to surface, provides an observation sample for other countries focusing on new financial forms and exposes the complex trade-offs involved in institutional innovation under real constraints. On a broader landscape, countries in the Middle East, Latin America, and others seeking financial diversification and attempting to reduce dependence on a single currency or payment system may very well view the combination of Belarus's High-Tech Park and cryptocurrency banks as a reference model, undergoing varying degrees of localization and replication in the coming years.
At least in the short term, the market's reaction to Decree No. 19 largely remains at the level of narrative and licensing expectations. The decree itself will not immediately change the flow of global capital; what will truly determine whether crypto capital flows into Belarus will be the transparency of subsequent compliance details, the consistency of enforcement, and the performance of regulatory cooperation with other jurisdictions. As these key pieces of the puzzle have yet to be fully revealed, whether this "cryptocurrency bank" experiment will prove to be a pioneering model of regulatory innovation or yet another high-leverage gamble layered on high-volatility assets remains an open question for time and the market to answer together.
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