On January 16, 2026, at 8:00 AM UTC+8, Belarusian President Alexander Lukashenko signed Decree No. 19, which for the first time explicitly grants "crypto banks" legal status at the level of sovereign states, bringing this business model, which originally operated on the fringes of regulation, into the view of the national financial system. The decree requires that entities wishing to become crypto banks must obtain the status of resident enterprises in the Belarus High-Tech Park and must also be registered in the crypto bank registry of the National Bank of Belarus, creating a dual threshold of industrial attributes and financial regulation. When the same institution is allowed to conduct traditional banking operations and financial services related to digital tokens under one licensing structure, the previously clear boundaries in the Eastern European financial landscape are actively blurred, raising a new issue surrounding regulatory arbitrage, institutional compliance, and regional competition: Is Belarus building a new transit hub for Eastern European funds, or is it laying the groundwork for its upcoming risk cycle?

Behind the Presidential Signature: The Convergence of Traditional Banking and Crypto Business

The core of Decree No. 19 lies in breaking the binary structure of financial services, allowing the same legal entity to operate traditional banking services such as deposits and loans, payments, as well as financial services related to digital tokens under a single regulatory identification. This means that within Belarus, banks no longer need to reach blockchain-related businesses through complex subsidiaries, offshore structures, or technology outsourcing, but can directly lay out their operations within the officially recognized business scope, transforming crypto assets from business appendages into legitimate subjects that can be included in operational lines. At the same time, the decree firmly ties these institutions to the mainstream regulatory system through the technical design of a "registry": any institution wishing to carry the crypto bank banner must be included in the crypto bank registry established by the National Bank of Belarus, which is equivalent to placing its crypto business under a prudential regulatory perspective similar to that of traditional banks. This is why the market has commented that "this is the first time a sovereign state has included crypto banks in the mainstream financial regulatory framework," viewing this policy as a turning point from 'tolerated innovation' to 'institutional shaping.' Lukashenko's signature is not just about empowering a new business model; it is also about delineating a boundary that can be held accountable and audited for the deep convergence of traditional finance and crypto finance.

High-Tech Park Support: A Combination of Tax Benefits and Licenses

To understand the focal point of this regulatory experiment, one cannot overlook the Belarus High-Tech Park as a policy testing ground. Years ago, the High-Tech Park had already received tax reductions, simplified administrative approvals, and special support for IT and innovative enterprises, serving as a key tool to attract software development and outsourcing industries. By limiting the subjects of crypto banks to "resident enterprises of the High-Tech Park," Decree No. 19 effectively locks the main carriers of crypto finance within a space that already has tax incentives and industrial policy foundations. For future crypto banks, this identity requirement means they can enjoy a package of traditional advantages such as income tax reductions, VAT benefits, and more relaxed talent and foreign exchange policies while exploring compliance. The combination of tax benefits and financial licenses creates a cumulative effect. In terms of regulatory design, the authorities attempt to firmly weld emerging crypto finance into the existing policy framework through a "High-Tech Park + National Bank Regulation" dual-track structure: on one hand, leveraging the park's experience to absorb the risks of technological innovation and enterprise incubation, and on the other hand, using the National Bank's registry and prudential regulation to incorporate fund safety, anti-money laundering, and system stability into the entire set of rules. Under this arrangement, crypto banks are no longer a technical concept floating outside the financial system but are embedded within a mature operational and regulatory network.

Differentiated Regulatory Competition in Eastern Europe: Who is Seizing the Gray Area?

From a geopolitical and regulatory perspective, crypto finance has become an important tool for Eastern European countries to engage in differentiated competition, with countries in the same region taking vastly different policy routes. Some lean towards Western standards, viewing crypto-related businesses as high-risk areas, curbing expansion through strict licensing, capital requirements, and rigorous review processes; others choose to maintain ambiguity in the regulatory gray area, sustaining a "can enter, can exit" ambiguous attitude through unclear legislation and passive enforcement. In contrast, Belarus's approach of legally granting crypto banks legal status and imposing hard constraints through the National Bank's registry clearly positions it on a more aggressive side, attempting to actively shape a new role in the regional financial landscape. In this context, the dual regulatory model is not only a technical detail of domestic institutional innovation but is also packaged as a "new business card" to attract regional institutions and family offices: for funds seeking compliance while wishing to retain a degree of asset privacy and flexibility, a jurisdiction that can complete traditional account management, custody, and on-chain asset services within the same institution is evidently more attractive than a single license. On a broader scale of capital flow, VC funds in 2025 are widely believed to be concentrating on leading projects and blue-chip assets, with risk appetite retreating from early high-volatility projects to targets with more safety cushions. At this time, Belarus's offering of institutional dividends clearly aims to use the combination of "clear regulation + tax incentives" to hedge against this conservative trend in capital, hoping to persuade some funds that should flow directly to mature markets to detour and view itself as a viable option.

The Temptation and Constraints of Dual Regulation: Opportunities and Uncertainties Coexist

For institutional investors, the greatest temptation of combining traditional banking licenses with crypto business lies in the significantly shortened compliance path, especially for those funds that must undergo external audits, internal risk control assessments, and custody constraints. Structurally, a crypto bank registered with the National Bank and also possessing the status of a resident enterprise in the High-Tech Park can theoretically meet the needs for fund custody, security audits, KYC, and on-chain operations simultaneously, reducing the compliance gap risks caused by the cross-coordination of multiple service providers in the past. Under this arrangement, the counterparties that institutions engage with are no longer technology companies or foreign entities, but a bank regarded as a "formal financial institution" in their home country, which provides substantial convenience for legal, audit, and LP communications. However, dual regulation also means higher costs and tighter constraints. Such institutions must not only meet traditional banking requirements for capital adequacy, liquidity, and risk management but also bear the unique volatility, technical security, and on-chain compliance risks associated with crypto assets, leading to a significant increase in the complexity of compliance reports, internal control construction, and risk disclosures. How to delineate business boundaries and how to ensure compliance in cross-border services will be difficult to answer in the short term. A more practical issue is that, based on currently available public channels, there is still limited English information about this system, and the details accessible to the outside world are far fewer than those covered by local legal texts. The evaluation that "the limited English information indicates that this policy is still in the early implementation stage" highlights a key risk: before it is truly implemented, the market will find it challenging to assess execution transparency and regulatory attitudes based on fragmented information, and the extent of the gap between institutional design and actual operation can only be passively verified through rounds of pilot programs.

Model or Isolated Case: The Open Ending of the Belarusian Model

Looking back at this round of operations in Belarus from the perspective of institutional puzzles, one can find its logic relatively clear: on one hand, formally incorporating crypto banks into mainstream financial regulation through the National Bank's registry and traditional banking framework; on the other hand, relying on the mature carrier of the High-Tech Park to provide tax and industrial policy support for such institutions, allowing financial innovation and existing industrial foundations to form a mutually supportive combination. This "regulation + park" dual-track structure not only reshapes the financial boundaries of the country but also provides an imaginative model for other emerging markets. However, the key variable that truly determines whether it can transition from "paper innovation" to a replicable model remains those details that have not yet been fully disclosed: how future implementation rules will define business scope and capital requirements, how many potential participants will be blocked by licensing thresholds, and when a batch of representative first institutions will enter the registry, all of which will directly affect the market's trust and reference value for this model. Before these questions have answers, the Belarusian model may be seen as a forward-looking experiment in Eastern European crypto financial regulation or classified as an isolated case under a specific political and industrial phase. As for whether other emerging markets will choose to follow suit with a similar dual regulatory framework, actively bringing crypto finance into their mainstream financial systems, or continue to rely on ambiguous legislation and selective enforcement to maintain regulatory gray areas, it may only become clear during the next round of global liquidity and regulatory cycles. For those seeking a balance between cross-border capital and asset allocation, Belarus's new gamble is worth continuous tracking, but the real moment to place bets has clearly not yet arrived.

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