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Mongolia

An early FATF-driven VASP law: 12 exchanges are registered with the FRC, and it is now pushing tugrik P2P trading onto them.

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12VASPs registered with the FRC
MNT 400MMinimum paid-in capital for each VASP service
100xMaximum client assets in custody relative to a VASP's equity

Mongolia regulated crypto because the FATF made it urgent.

Local exchanges were already trading in tugrik when the FATF put Mongolia on its grey list in October 2019 for weak anti-money laundering controls.

Mongolia left the list in October 2020, and on 17 December 2021 Parliament passed the Law on Virtual Asset Service Providers, one of the first dedicated VASP statutes in Asia.

Read the full story

The law hands the Financial Regulatory Commission (FRC) a registration regime rather than a full licensing code.

Only companies incorporated in Mongolia may register, and five activities are covered: exchanging virtual assets for fiat or for each other, transfers, custody, and organising public offerings of virtual assets.

After a transition period the FRC registered its first three exchanges, Digital Exchange Mongolia, CoinHub and Idax, on 21 September 2022.

The market has stayed small and domestic.

The FRC's register listed 12 VASPs in 2023, and the FRC said in May 2026 that 12 were still operating, while much retail trading had moved to unregulated peer-to-peer deals on foreign platforms.

After repeated FRC requests, Binance P2P stopped person-to-person tugrik trades from 1 June 2026 and now lets only FRC-registered VASPs serve tugrik customers as Pro-Merchants.

The FRC repealed most of its 2022 rulebook with Resolution No. 657 of December 2024 and the last piece, the supervision rules, in June 2026.

Its current operating regulation, Resolution No. 258 of 25 June 2026, keeps MNT 400 million of paid-in capital per service and requires a five-member board with two independent directors.

For builders, Mongolia is open but demanding for its size: capital must be cash and not borrowed, each added service needs another MNT 400 million, and custody is capped at 100 times a firm's equity.

There is no stablecoin, tokenisation or crypto tax framework yet, so projects beyond exchange, transfer and custody work in grey space.

Watch for FRC enforcement against unregistered P2P dealers and for any move to bring stablecoins into the law.

Who regulates

  • FRCFinancial Regulatory Commission

    In charge of

    Mongolia's regulator for financial services outside banking. It licenses and supervises the securities market, insurers, non-bank financial institutions and savings and credit cooperatives.

    On crypto

    Registers VASPs under the 2021 Law on Virtual Asset Service Providers (12 as of 19 May 2026) and sets their rules; Resolution No. 258 of June 2026 requires MNT 400 million capital per service and a five-member board. It pressed Binance P2P to limit tugrik trades to registered VASPs from 1 June 2026.

    FRC website
  • BoMBank of Mongolia

    In charge of

    Mongolia's central bank. It sets monetary policy to keep the tugrik stable, licenses and supervises banks, and oversees payment systems and electronic money.

    On crypto

    Has no licensing role over VASPs, which sit with the FRC. The VASP law excludes digital fiat currency and the electronic money it regulates from the definition of virtual assets, and there are no stablecoin rules. It houses the Financial Information Unit.

    BoM website
  • FIUFinancial Information Unit (Bank of Mongolia)

    In charge of

    Mongolia's financial intelligence unit, operating within the Bank of Mongolia. It receives and analyses suspicious and cash transaction reports and passes intelligence to law enforcement.

    On crypto

    Treats registered VASPs as reporting entities and publishes a suspicious transaction reporting manual, a risk-based approach guide and red-flag indicators for virtual assets. Its work supports the AML controls that took Mongolia off the FATF grey list in October 2020.

    FIU website

What to watch

  • How the FRC enforces against unregistered P2P dealers after Binance restricted person-to-person tugrik trading on 1 June 2026.
  • Implementation of FRC Resolution No. 258 of 2026, which now sets the capital, governance, auditor and professional association requirements, and whether existing registrants meet its board and governance requirements.
  • Any amendment to the VASP law to cover stablecoins, tokenised assets or crypto taxation, none of which it addresses today.

Quick answers

Who regulates crypto in Mongolia?

Three authorities shape crypto rules in Mongolia. FRC (Financial Regulatory Commission): registers and supervises virtual asset service providers and sets their capital, governance and reporting rules. BoM (Bank of Mongolia): central bank; virtual assets exclude digital fiat and e-money it licenses. FIU (Financial Information Unit (Bank of Mongolia)): receives suspicious transaction reports from VASPs and issues their AML/CFT guidance.

Do crypto exchanges need a licence in Mongolia?

Yes, under a dedicated regime. FRC registration for exchange, transfer, custody and offerings since 2022; 12 registered VASPs. The licence is FRC Virtual Asset Service Provider registration from FRC, held by 12 as of 19 May 2026. Four Pillars rates exchange licensing in Mongolia as comprehensive (reviewed 5 Oct 2026).

Are stablecoins regulated in Mongolia?

Not fully yet: the regime is being built. No stablecoin rules; the VASP law covers trading, transfers, custody and offerings only. Four Pillars rates its stablecoin regime in Mongolia as developing (reviewed 5 Oct 2026).

How is crypto taxed in Mongolia?

No crypto-specific tax rules; general income and corporate tax laws apply. Four Pillars rates tax clarity in Mongolia as developing (reviewed 5 Oct 2026).

Can real-world assets be tokenised in Mongolia?

Yes, though the regime is narrow or still phasing in. Public virtual asset offerings must go through a registered VASP; tokenised securities are excluded. Four Pillars rates tokenisation and real-world assets in Mongolia as partial (reviewed 5 Oct 2026).

What changed most recently in Mongolia's crypto rules?

25 Jun 2026: FRC adopts a new VASP operating regulation. Resolution No. 258 keeps MNT 400 million capital per service and the 100x custody cap, and sets board, listing and market abuse requirements. 19 May 2026: FRC warns against unregistered P2P trading. It said 12 VASPs were registered and that Binance P2P would restrict person-to-person tugrik trades from 1 June 2026.

What should companies watch next in Mongolia?

How the FRC enforces against unregistered P2P dealers after Binance restricted person-to-person tugrik trading on 1 June 2026. Implementation of FRC Resolution No. 258 of 2026, which now sets the capital, governance, auditor and professional association requirements, and whether existing registrants meet its board and governance requirements. Any amendment to the VASP law to cover stablecoins, tokenised assets or crypto taxation, none of which it addresses today.

Timeline

  1. FRC adopts a new VASP operating regulation

    Resolution No. 258 keeps MNT 400 million capital per service and the 100x custody cap, and sets board, listing and market abuse requirements.

  2. FRC warns against unregistered P2P trading

    It said 12 VASPs were registered and that Binance P2P would restrict person-to-person tugrik trades from 1 June 2026.

  3. FRC replaces its 2022 rulebook

    Resolution No. 657 approved a new operating regulation and repealed the 2022 registration, operating, auditor, association and restriction rules.

  4. First three VASPs registered

    Digital Exchange Mongolia, CoinHub and Idax were registered, followed by six more on 10 October 2022.

  5. FRC completes the VASP rulebook

    Registration, auditor and association rules (April) were followed by supervision and restriction and deregistration rules on 25 May 2022.

  6. FRC issues its first VASP operating regulation

    Resolution No. 175 set governance, custody and Travel Rule requirements.

  7. Parliament passes the Law on Virtual Asset Service Providers

    It requires VASPs to be Mongolian companies registered with the FRC.

  8. Mongolia leaves the FATF grey list

    The FATF found Mongolia had completed its action plan.

  9. FATF puts Mongolia on its grey list

    Mongolia agreed an action plan to fix strategic AML/CFT deficiencies.

Cite this page: Four Pillars Asia Digital Asset Policy Center, “Mongolia crypto regulation”, reviewed 5 Oct 2026, https://policy.4pillars.io/mongolia. Free to reuse with attribution; also as markdown and JSON.

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