One market. Distinct business models.
Exchanging assets for customers, operating a trading venue and investing company funds are different objectives. The activities determine the regulator, permissions, capital, team and banking arrangements.
VM.Capital helps align your product with a suitable legal model in Kyrgyzstan. We start with customers and the flow of money and assets, then assess the registration framework and preparation steps.
Explore All Business SolutionsDefine what the company will actually do
Customer exchange services
Purchasing, selling or exchanging virtual assets in customer transactions. Define counterparties, assets, settlement and the source of revenue.
Trading venue
Arranging participant interaction and transactions under venue rules. Separately assess access, order execution, settlement and custody.
Own-asset transactions
Acquiring, holding and disposing of company assets. Distinguish own-account investment from professional dealing: using own funds does not automatically remove licensing requirements.
Assess customer-asset custody, brokerage, portfolio management, token issuance and mining separately. A permission for one activity cannot be extended to every service.
Kyrgyz national framework: exchange and venue operations differ
Virtual asset exchange operator
The activity requires licensing and entry in the relevant register. Assess operations and requirements of the Financial Market Regulation and Supervision Service, known as Finnadzor.
Virtual asset trading operator
A crypto exchange venue has a separate regulation and register. Exchange-operator requirements cannot substitute for venue requirements. First establish whether the product organises trading between participants.
Other activities need their own assessment: mining has a registration and certificate route, while virtual-asset issuance has separate procedures. The selected model and current rules determine the required steps.
Start by defining the activities
Tell us which services you plan to offer and to whom. We can identify the permissions and conditions to review before incorporation and platform development.
Tamchy SFIT: a separate regulatory route
Digital-asset activities in Tamchy follow the SFIT framework and its Financial Regulator. Incorporation and status do not replace authorisation for regulated activities.
Venues and custody
Operating an exchange and providing digital-asset custody are separate licensed activities. Identify functions performed internally and those provided by external firms.
Dealing and brokerage
Principal dealing and agency execution are specified categories. Professional own-account dealing cannot be treated as unlicensed merely because of the funding source.
Other services
Portfolio management, digital-asset advice and stablecoin issuance have their own regulatory assessment. Distinguish technology development from financial services.
Finnadzor and SFIT permissions are not treated as interchangeable. Separately assess territorial scope, customer countries and access to external venues and banking infrastructure. Other markets may require further permissions and approvals.
How to choose the framework
Activities and permissions
Map activities to a specific category in each framework. Review permitted assets and services, restrictions and the need for multiple permissions.
Ownership and governance
Corporate form, capital, ultimate owners, leadership and control functions. For SFIT, separately confirm registration, status, presence and governance conditions.
Ongoing costs
Capital, fees, staffing, information security, reporting and audit. Compare real operating costs; tax relief alone should not determine the choice.
SFIT relief has a defined scope and does not automatically remove external taxes or social obligations. HTP does not replace financial authorisation: any status for a separate software developer is assessed against its own activities.
What to organise before launch
A verifiable structure
Owner documentation, capital sources, management authority and responsibilities. Corporate disclosures should reflect actual control.
Customers and source of funds
Customer and beneficial-owner checks, sources of money and assets, sanctions exposure and transaction risks. Define evidence, risk indicators and response procedures.
Platform and security
Access and key management, transaction approvals, data retention, backup and recovery. Where customer assets are involved, separately define accounting and separation from own assets.
Banks and counterparties
Prepare a clear account of activities, permissions and funds flows. A licence does not guarantee an account or venue access: each partner conducts its own review.
Contracts and rules
Service terms, fees, execution, refunds and complaints. Define the respective obligations of the company, customers and external suppliers.
Accounting and oversight
Account for asset and cash transactions, fees, costs and obligations. Maintain reporting, controls and audit to the applicable extent.
How VM.Capital supports the project
01 · Assessment
Review the product and activities, compare legal models and frameworks. Identify issues for the regulator, banks and technology team.
02 · Preparation
Agreed incorporation steps, corporate documents, policies and application materials. Support engagement with the competent authority and responses to enquiries.
03 · Ongoing support
Accounting, tax and corporate matters within the agreed scope. Help update documentation as the product, ownership or requirements change.
Authorities and partners decide on licensing, accounts and connections. We support the process without guaranteeing approval, payments or freedom from restrictions.
A real engagement: supporting a virtual-asset business
In a published engagement, VM.Capital supported company formation in Kyrgyzstan and the licensing process for a virtual-asset business. Identifying client information remains confidential under an NDA. The case describes a particular completed engagement and does not determine future regulatory outcomes.
Explore the CaseExplore a suitable model
Start with your objective and proposed activities. We can help define the first preparation stage and the issues to resolve before investing in launch.