Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the FRC decision, including banking and payment rails.
Get a crypto license in Mongolia.
Mongolia licenses crypto, and has for years. The Law on Virtual Asset Service Providers took effect on 1 March 2022, and the Financial Regulatory Commission has run a live register since - about 12 licensed providers were serving over 900,000 user accounts by mid-2023. We build the file end to end.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Crypto licenses obtainedlicenses obtained
Updated
Mongolia in brief
A VASP register that has run since 2022.
Mongolia moved early and quietly. Parliament adopted the Law on Virtual Asset Service Providers on 17 December 2021, the law took effect on 1 March 2022, and the Financial Regulatory Commission - the FRC - has registered and licensed providers ever since. The regime covers the service layer, meaning exchanges, trading platforms, wallet and custody providers and transfer services, rather than the coins themselves. Licensed VASPs carry real AML and KYC duties and report to the Financial Information Unit at the Bank of Mongolia. The FRC filled in the operating detail fast: registration and operation procedures on 6 April 2022, inspection and deregistration procedures that May.
The register is not theoretical. By mid-2023 about 12 entities held licences, more than 200 virtual assets were registered on licensed platforms, and licensed providers served over 900,000 user accounts - in a country of about 3.5 million people. Behind that sits a mineral-rich economy wedged between Russia and China, with a young, phone-first population and entry costs far below the usual licensing centres. The working entity is a Mongolian LLC, and corporate tax is progressive: 10% on annual profit up to about MNT 6 billion, 25% above it. We prepare the whole file - company, policies, FRC application - end to end.
Mongolia has licensed crypto since 1 March 2022 under the VASP Law, with the FRC running the register and AML reporting to the FIU at the Bank of Mongolia.
By mid-2023: about 12 licensees, 200+ registered assets, 900,000+ user accounts. Entity: Mongolian LLC. Corporate tax 10% up to about MNT 6 billion, then 25%.
The regime
FRC registration and licensing, by service.
The VASP Law regulates the providers, not the coins. The FRC registers a company as a VASP and licenses the services it will run - the first job is scoping which services your model needs, the second is building a file the FRC will pass. We do both.
The FRC registers the company and licenses the services - exchange, platforms, custody, transfer. We scope which your model needs.
01 - VASP LAW · TRADING
Exchange and trading platforms
The core of the register: platforms that exchange virtual assets against the tugrik or against each other. More than 200 virtual assets were registered on licensed platforms by mid-2023 - this is where most Mongolian VASPs sit.
The core of the register: platforms that exchange virtual assets against the tugrik or against each other. More than 200 virtual assets were registered on licensed platforms by mid-2023 - this is where most Mongolian VASPs sit.
- ✓Exchange between virtual assets and fiat
- ✓Exchange between virtual assets
- ✓Operating a trading platform
- ✓Listing and registration of traded assets
- ✓AML/KYC with FIU reporting
- ✓Ongoing FRC supervision
02 - VASP LAW · CUSTODY & TRANSFER
Register live since 2022Wallets, custody, transfer
The law also reaches safekeeping and movement: custodial wallets, administration of virtual assets for clients and transfer services, plus participation in issuance-related financial services - each licensed as its own activity.
The law also reaches custody, administration, transfer and issuance-related services - each licensed as its own activity.
- ✓Custodial wallet and safekeeping services
- ✓Administration of client virtual assets
- ✓Transfer of virtual assets
- ✓Issuance-related financial services
- ✓Safeguarding and key management
- ✓One regulator - the FRC
Costs and timelines are confirmed for your case before any work begins. The FRC scopes capital and requirements by service; Mongolian entry costs are modest by licensing-centre standards, and the real investment is the file.
Why Mongolia
A working register, not a promise.
The framework rests on the VASP Law, in force since 1 March 2022 and supervised by the FRC - with several years of licensed providers and real users behind it.
✓
Years of licensing practice
The law took effect in March 2022 and the FRC has registered providers since June that year. You apply into settled procedures with precedent, rather than a regime still writing its own forms.In force since March 2022 - settled procedures.
✓
Real licensees, real users
About 12 licensed entities, 200+ registered virtual assets and over 900,000 user accounts by mid-2023. The register works at scale for the market it serves, and that record answers the questions banks ask.~12 licensees, 900,000+ accounts by mid-2023.
✓
One regulator - the FRC
The Financial Regulatory Commission handles registration, licensing and supervision, with AML reporting to the FIU at the Bank of Mongolia. One counterparty, one set of procedures, one file to defend.One counterparty, one file to defend.
✓
Between two giant markets
Mongolia sits between Russia and China with a mineral-driven economy and a young, phone-first population. It is a distinct base - useful for models that want Asia exposure outside the crowded centres.A distinct base outside the crowded centres.
✓
Low entry costs
A Mongolian LLC, local staffing and office costs priced for Ulaanbaatar rather than Singapore or Dubai. The licence budget goes into the file and the substance, not the rent.Priced for Ulaanbaatar, not Dubai.
✓
Progressive 10-25% tax
Corporate tax runs at 10% on annual profit up to about MNT 6 billion and 25% above that line. Most new licensees spend their early years entirely in the 10% band.10% up to ~MNT 6bn; 25% above.
How it compares
How Mongolia differs from other routes.
Mongolia is the quiet incumbent of the region - a VASP register running since 2022 with real users on it. The honest comparison is below.
Mongolia vs other jurisdictions
| Feature |  Mongolia | Other jurisdictions |
|---|---|---|
| Regulatory regime | VASP Law 2021 (FRC) | Varies - licence or registration |
| Maturity | Live register since March 2022 | Varies |
| Users on licensed platforms | 900,000+ accounts by mid-2023 | Ranges widely |
| Corporate tax | 10-25% progressive | Ranges widely |
Regulatory regime
MongoliaVASP Law 2021 (FRC)
Other jurisdictionsVaries - licence or registration
Maturity
MongoliaLive register since March 2022
Other jurisdictionsVaries
Users on licensed platforms
Mongolia900,000+ accounts by mid-2023
Other jurisdictionsRanges widely
Corporate tax
Mongolia10-25% progressive
Other jurisdictionsRanges widely
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Mongolia | VASP licence (FRC) | 10-25% corporate | Live register since 2022 |
 Kazakhstan | AIFC licence (AFSA) | 20% corporate | AIFC-based, supervised |
 Uzbekistan | NAPP licence | 15% corporate | Decree-based, licensed |
 South Korea | VASP registration (FIU) | 9-24% corporate | Strict, bank-tied |
MongoliaLicense typeVASP licence (FRC)
Taxation10-25% corporate
RequirementsLive register since 2022
KazakhstanLicense typeAIFC licence (AFSA)
Taxation20% corporate
RequirementsAIFC-based, supervised
UzbekistanLicense typeNAPP licence
Taxation15% corporate
RequirementsDecree-based, licensed
South KoreaLicense typeVASP registration (FIU)
Taxation9-24% corporate
RequirementsStrict, bank-tied
Before you apply
Requirements for the VASP licence.Requirements for the VASP licence.
The FRC reviews a VASP file against the 2021 law and the procedures it adopted in April and May 2022. The checklist below is what a passing file is built around - each item confirmed against current FRC practice.
01
Mongolian entity - a locally incorporated LLC with genuine presence and management in Mongolia.
02
FRC registration - the company entered on the VASP register before services begin.
03
Licensed service scope - the specific virtual-asset services your model needs, defined and applied for.
04
Fit & proper management - competent directors and officers with clean records.
05
Capital - as the FRC requires for your services and risk profile.
06
AML/KYC framework - identification, monitoring and reporting to the FIU at the Bank of Mongolia, with a named officer.
07
Safeguarding of client assets - segregation, custody policy and key-management design.
08
Governance - ownership disclosed to UBOs, conflicts, complaints and consumer-protection procedures.
09
Systems and security - technology and record-keeping the FRC can inspect, built to its operation procedure.
10
Business plan - services, volumes and financials the FRC can interrogate.
11
Wind-down plan - credible and documented.
01
Mongolian LLC with genuine presence.
02
FRC registration before services begin.
03
Licensed service scope, defined and applied for.
04
Fit & proper directors and officers.
05
Capital - as the FRC requires.
06
AML/KYC with FIU reporting, named officer.
07
Safeguarding of client assets.
08
Ownership disclosed to UBOs.
09
Systems the FRC can inspect.
10
Business plan the FRC can test.
11
Credible wind-down plan.
Reflects the Law on Virtual Asset Service Providers (in force 1 March 2022) and FRC procedures as of 2026. Providing virtual-asset services without FRC registration is prohibited under Mongolian law.VASP Law (1 March 2022) + FRC procedures, as of 2026.
How it works
From first call to the FRC licence.
01
Perimeter and strategy
We map your services to the VASP Law's activities and fix scope, capital and timeline in writing against the FRC's procedures.Services, scope, capital - in writing.
02
Mongolian company and substance
Local incorporation, registered office, directors and the governance layer - the presence the FRC assesses behind the file.Local incorporation, office, directors.
03
The application file
AML/KYC framework, safeguarding and systems documentation, business plan and capital - assembled to the FRC's standard.AML, safeguarding, plan, capital - FRC-grade.
04
FRC review
Registration and licensing rounds with the FRC - we answer every question and carry the file to the decision.Registration and licensing rounds - answered.
05
Licence and operations
The VASP licence granted and the business live, with ongoing FIU reporting and FRC duties we can keep running.Licence granted; ongoing duties we can run.
Quick facts
RegulatorFRC
FrameworkVASP Law 2021
In force1 March 2022
Registration openSince 25 June 2022
LicenseesAbout 12 by mid-2023
User accounts900,000+
Corporate tax10% / 25%
SubstanceMongolian LLC + presence
The register has run for several years - the FRC knows what a passing file looks like, and so do we.
On the ground in Mongolia
Run from our Dubai office, with Mongolian counsel.
Prifinance - Mongolia desk
Ulaanbaatar · Mongolia
Ulaanbaatar, Mongolia
01
Mongolian incorporation
LLC formation and the corporate layer the FRC expects - structured for VASP registration from day one.LLC built for VASP registration.
02
The licence file
AML/KYC pack, safeguarding and systems documentation, business plan and capital - drafted by us to the FRC's 2022 procedures.AML, safeguarding, plan, capital - to standard.
03
Substance and staffing
Directors, a named compliance officer and the Ulaanbaatar presence the licensed services require - assembled at local cost levels.Compliance officer, local presence, local costs.
04
Banking and operations
Accounts arranged on full disclosure, matched to tugrik and cross-border flows - the licensed business live on rails that hold.Accounts on disclosure; live on solid rails.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of crypto companies in Mongolia.
Company profits are taxed progressively - 10% up to about MNT 6 billion a year, 25% above - which keeps most new licensees at the lower rate for years.
Progressive 10-25% rate
Corporate income tax is 10% on annual taxable profit up to roughly MNT 6 billion, then 25% on the excess. A new VASP typically models the 10% band for its early years.10% to ~MNT 6bn profit; 25% above.
VAT at 10%
Mongolia's VAT runs at 10% on domestic supplies of goods and services. How it maps onto fee income is planned into the model rather than assumed away.Planned for, not assumed away.
Withholding on cross-border flows
Payments to non-residents can attract 20% withholding under Mongolian rules, treaty-dependent. For a licensed business with foreign counterparties, we structure the flows so the outcome is deliberate.20% on non-resident payments, treaty-dependent.
Personal income tax from 10%
Personal income tax starts at 10%, with higher bands for large annual incomes - relevant at the owner and staff level, modelled alongside the company position.From 10% - modelled with the company.
Priced for Ulaanbaatar
Office, staff and service costs sit far below the usual licensing centres, so the operating model carries the tax comfortably. The draw is the register, not a zero-tax pitch.Low operating costs carry the tax.
Records serve both
The AML and FRC record-keeping the licence requires also underpins the tax position - regulator-grade books double as tax-office-grade books.Regulator-grade books serve tax too.
Tax summary
Corporate income tax10% / 25% (MNT 6bn line)
VAT10%
Non-resident withholding20%, treaty-dependent
Personal income taxFrom 10%
CurrencyMNT (tugrik)
Crypto-specific rulesVia VASP Law regime
*As of 2026. The threshold and rates follow Mongolia's Corporate Income Tax Law - we model the position honestly around the licence.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Mongolian company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, FRC-licensed business.
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Mongolia · FRC
Launch your crypto project in Mongolia with expert support.
Full-service assistance - from company registration to the VASP licence and ongoing compliance.
Get a consultation →Free legal opinion
Is Mongolia the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which licence scope or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Mongolia crypto licence, answered.
Does Mongolia license crypto?+
Yes - under the Law on Virtual Asset Service Providers, adopted on 17 December 2021 and in force since 1 March 2022. The FRC registers and licenses providers, and the register has held real licensees for years.
What does the licence cover?+
The services, not the coins: exchange between virtual assets and fiat or each other, trading platforms, custodial wallets and safekeeping, transfer and issuance-related financial services. We scope the exact set your model needs.
How established is the regime?+
By mid-2023 about 12 entities held licences, over 200 virtual assets were registered on licensed platforms and licensed providers served more than 900,000 user accounts. This is a register with operating history, in a country of about 3.5 million.
Who supervises licensed VASPs?+
The Financial Regulatory Commission registers, licenses and inspects providers under procedures it adopted in April and May 2022. AML reporting runs to the Financial Information Unit at the Bank of Mongolia.
How much capital is required?+
The FRC sets capital by service and risk profile, so there is no single figure. We scope your capital against the FRC's current procedures for your specific services rather than quote a generic number.
What substance does the FRC expect?+
A Mongolian LLC with genuine presence and management: fit-and-proper directors, a named compliance officer and systems the FRC can inspect. Local costs are modest, which makes real substance affordable here.
How are crypto companies taxed?+
Progressively: 10% corporate tax on annual profit up to about MNT 6 billion, 25% above it. VAT is 10%, and payments to non-residents can carry 20% withholding. Most new licensees sit in the 10% band.
Why Mongolia rather than a bigger centre?+
Because the register works and the costs are low. Several years of licensing practice, real users on licensed platforms and an economy between two giant neighbours - for the right model, that beats queueing in a crowded hub.
Does Mongolia license crypto?+
Yes - VASP Law, in force since 1 March 2022.
What is covered?+
Exchange, platforms, custody, transfer - the services.
How established?+
~12 licensees, 900,000+ accounts by mid-2023.
Who supervises?+
The FRC, with FIU reporting at the Bank of Mongolia.
Capital?+
Set by the FRC, by service and risk.
Substance?+
Mongolian LLC, real presence and compliance.
Company taxes?+
10% to ~MNT 6bn, 25% above; VAT 10%.
Why Mongolia?+
A working register at low cost, since 2022.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
Google
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Google
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which licence scope or route fits your business.Free legal opinion: which Mongolia licence scope fits your project and what it will cost.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Financial Regulatory Commission of Mongolia, the Bank of Mongolia or any other public authority. Licences are granted by, and obtained directly from, the competent authorities.