Market / Uzbekistan  ·  Frontier & Gulf

Uzbekistan: the programme behind the licence. The licence is the easy part.

Uzbekistan is opening on its own terms. A dedicated agency runs the new regimes for crypto, funds and gaming. The central bank is rebuilding its financial-monitoring reach across banking and payments. A prosecutor-led financial intelligence unit pulls real estate, dealers and high-value trade inside the AML perimeter. A permit from any of them is the start, not the finish. What a supervisor tests is the AML/CFT and sanctions programme behind that permit. Black Sea builds, remediates and runs that programme. Operator-side only: we licence nothing, sell no software, take no commission. We are the reviewer, not the seller.

Theatre Frontier & Gulf NAPP · CBU · DCEC · MIIT DCEC / national FIU Operational
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FRONTIER & GULF
6
Supervisory bodies
2
Authorisation channels
9
Sectors covered
1
FIU / DCEC
02

There is no single Uzbekistan regulator

Uzbekistan splits supervision across a specialised agency, the central bank and a prosecutor-led financial intelligence unit. The distinction that matters: a regime that authorises through a dedicated register versus one that licenses or registers through the central bank, over a single national AML backbone run by the FIU. The bodies that matter are set out below. No date, deadline, threshold or penalty is asserted here.

VASP, funds & gaming
NAPP The National Agency for Prospective Projects is the dedicated authority for virtual-asset service providers, fund and corporate-service activity, and gaming. NAPP authorises these operators and maintains a public register of admitted service providers. It is a permissioned regime: the activity is lawful only through a NAPP-admitted provider. We confirm any specific prohibition or scope condition with the regulator before we state it.
Banks & payments
CBU The Central Bank of the Republic of Uzbekistan licenses and supervises banks and credit organisations, and registers and oversees payment organisations and the money-services space. Banks sit under a licensing regime on the register of credit organisations; payment organisations sit under a registration regime with their own public register. Different thresholds, but both carry the full AML/CFT obligation.
Financial monitoring
CBU FMD The Financial Monitoring Department carries the central bank's AML/CFT financial-monitoring function across banking and payments. It is the supervisory monitoring layer over CBU-regulated institutions.
FIU & DNFBP AML
DCEC The Department for Combating Economic Crimes, under the Prosecutor General's Office, is the national financial intelligence unit and specially authorised AML body. Suspicious-transaction reporting runs here. It sits behind the DNFBP perimeter, including real estate and high-value dealing, and is the common reporting endpoint that ties the regime together.
Precious metals
Asillik The Inspectorate of State Assay Control, under the Ministry of Economy and Finance, oversees hallmarking and assay control for the precious-metals trade. The AML obligation for those dealers still runs to the DCEC.
Export control
MIIT The Ministry of Investment, Industry and Trade is the authority for the defence and dual-use export-control side.
Uzbekistan's framework is moving quickly and several regimes are young. We ground every reference in the current published framework, verify any recent rule change with the named regulator before building to it, and never assert a specific deadline, penalty or statute number without a source.

Uzbekistan draws a specific mix of regulated operators: NAPP-admitted crypto exchanges, fund managers and gaming operators; banks and payment organisations under the central bank; gold and dual-use exporters trading across a sensitive region; and DNFBP firms inside the AML perimeter via the DCEC as national FIU. A permit from NAPP, the CBU or a sector authority obliges each to build and run a real programme:

01A risk assessment that reflects the actual customer base, geographies and products, not a template.
02Customer due diligence and enhanced due diligence that hold up under file review, including beneficial-ownership and source-of-funds work.
03Transaction monitoring, plus suspicious-transaction reporting into the DCEC as the national FIU.
04Sanctions and export-control screening calibrated to Uzbekistan's regional exposure and the firm's counterparties.
05A named MLRO, governance, board reporting, staff training and independent testing.
Supervisors do not assess intentions. They assess evidence: files, alerts, decisions, reports and the record that the programme worked. That evidence is what we build.
01
Licensing and new-regime programme build. The full AML/CFT and sanctions programme behind a NAPP, CBU or sector permit: risk assessment, policies, controls, screening, the reporting line into the DCEC, ready for regulator review.
02
Remediation. Post-finding or post-enforcement clean-up: root-cause work, file remediation, control redesign and the evidence trail a supervisor will want to see.
03
Outsourced and bridge MLRO, plus a managed FIU function. A senior officer and a working financial-intelligence function while you recruit, restructure or scale.
04
Independent AML audit. The independent test the framework expects, delivered by a reviewer with no stake in the outcome.
05
Sanctions, export-control and integrity due diligence. Screening and diligence calibrated to Uzbekistan's regional and counterparty exposure, including the Travel Rule for virtual-asset firms.
Fixed scope. Fixed fee. No hourly billing. A costed plan within 48 hours.
Full scope of what we do →
A new regime, read correctly
NAPP's virtual-asset framework and the central bank's financial-monitoring reach are young and still tightening. We read the current rules as written and build to them, not to a stale template.
One programme across the perimeter
A firm touching NAPP, the CBU and the DCEC gets a single coherent programme reporting into one FIU, not three disconnected ones.
Independent and conflict-free
We sell no permits and no software, so our review answers to the regulator's standard, not a sales target.
Senior-only
The people who scope your programme are the people who build it. No junior hand-off.
Briefing seriesCurrent and datedA running series tracking frontier and Gulf AML/CFT and sanctions regimes as they move.Insights →
Local partnersLocal legal standingLicensed local law-firm and compliance partners in our markets.Partners →
Press pickupKazakh pressIndependent coverage of our work, not paid placement.The record →
CredentialsCAMS / ICAReal proof, current and verifiable. No client names, no invented cases.The firm →

If you licence, hold, pay or report in Uzbekistan, the programme is what gets inspected.

Tell us the permit, the sector and where the programme stands today. You get a costed, fixed-scope plan within 48 hours.
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