1. [Legal Business Permissions and Supervision Mechanism] of Mongolian VASP License
Five statutory business categories
Article 6.1 of the Act expressly covers：Fiat currency exchange、Cryptocurrency trading、Asset transfer、Asset custody and administration，and financial services participating in public offerings or sales (ICO/IEO)。
100times the custody leverage red line
Disguised reserve requirement system。Total virtual assets held and administered by VASP，The legal upper limit must not exceed its own capital (Capital Equity) 100 times，Quarterly assessment。
VAT exempt (VAT)
The income of virtual asset exchange and trading service providers must file tax returns and pay income tax in accordance with the law.，However, this part of business income is exempt from value-added tax (VAT) according to law.。
Seamless integration with FATF standards
Mongolia is the fifth country in the world to fully comply with FATF 40recommended countries。Strictly enforce “travel rules”(Travel Rule) landing，Highly internationally recognized in preventing money laundering and fraud risks。
2. Mongolia VASP [Industry Approval Cases and New Statutory Supervision Regulations]
comprehensive exchange：Denode / Trade.mn
Denode relies on AND Global Group，Launching real world assets (RWA) Tokenization services。Trade.mn is Mongolia’s first crypto exchange，The first batch was issued VASP license，Issue official platform currency TRD。
Financial Groups and Consumer Finance：DAX / Store Pay
ArdCoin is issued on the DAX exchange under the Ard Group。Store Pay combines installment payment business to issue SPC coins，Compliant offering via VASP exchange，Willcryptocurrencyandconsumer creditDeep integration。
Exclusive chartered audits and on-site inspections
2023Since，The FRC only recognizes firms that are officially chartered and registered (requiring a capital of NT$30 million and 4 resident auditors) to conduct financial audits of VASPs。2024Guidelines to be released in 2019，Regular on-site inspections。
Operational procedures simplification and sandbox upgrade
2025The FRC released the 74 Resolution No. 1 to delete and streamline the administrative procedures of the "Operating Regulations"。Also upgrade the regulatory sandbox legal framework，strengthenAnti-money launderingRequire，Testing for the purpose of evading supervision is strictly prohibited。
3. Mongolia VASP’s [Statutory Capital Requirements and Fund Localization Standards]
| Statutory capital and threshold categories | Interpretation of statutory requirements and regulatory bottom line |
|---|---|
| Minimum paid-up share capital (Share Capital) | Applicants who carry out core regulated services，Its share capital shall not be less than 4Yitugrik(approximately 115,000 – 11.7million U.S. dollars)。If you apply for multiple virtual asset services，The minimum share capital requirement will be increased on a case-by-case basis according to business regulations.。 |
| Foreign investment access threshold | For foreign-invested enterprises (foreign investors hold 25% or more of the shares)，The minimum investment amount for each foreign investor must be 10million dollars。 |
| Fund purity and localization restrictions | Share capital must consist of legal monetary assets，Loans are strictly prohibited。When calculating paid-in capital and own capital，Absolute prohibition on including assets registered overseas(Aimed to ensure FRC’s actual control over assets and liquidation rights)。 |
4. [Corporate governance and qualifications under the FRC (Fit & Proper) Review standards]
Local content and physical office：The applicant must be a corporate entity legally registered in Mongolia，Natural persons are strictly prohibited。Proof of actual physical office address in Mongolia (real estate ownership certificate or notarized lease contract) must be provided when applying for registration.，FRC will conduct on-site verification。
Board Structure and Statutory Departments：Must be established by at least 5 board of directors，which contains at least 2 independent directors。An independent internal audit department must be established、IT department、Customer service department and dedicated AML/CFT compliance supervision department (or full-time compliance officer)。
Ban on executive part-time jobs (exclusivity)：Department heads or persons responsible for offering and trading virtual assets to the public，Unless otherwise provided by law，Not allowed to engage in dual employment (part-time job)，To prevent insider trading and profit transfer。
Penetrating eligibility review：Executive management and shareholdings 5% The above actual controller must have a professional background in finance/law/IT and other fields；No record of overdue debts；Absolutely exclude money laundering、Persons convicted of terrorist financing and major economic crimes。
5. [List of statutory review documents submitted to Mongolia FRC]
| File category | Submission details of statutory requirements and interpretation of regulatory key points |
|---|---|
| Basic Corporation and Tax Certification | Original/notarized copy of national registration certificate and company articles of association。Notarized copy of office property certificate or lease contract。Certificate of no overdue tax arrears issued by the tax bureau。Foreign-invested enterprises need to provide proof of no crime and no tax arrears in the country of origin in the past 10 years。 |
| Business and Financial Compliance Planning | four-year business development plan。Draft customer agreement (must contain mandatory disclaimer and extreme risk disclosure clauses)。Audited financial reports for the past three years (balance sheet provided for new establishments)。Independent bank account opening agreement for segregating client funds。 |
| System technology and risk control internal control documents | Network Security Program and IT Infrastructure Technical Audit Report。AML/CFT risk assessment report、Mitigation action plans and internal control procedures。Business Termination and Liquidation Contingency Plan。 |
6. [Statutory Application and FRC Approval Procedures] for VASP License in Mongolia
first stage：Corporate establishment and tax registration
at the National Registration Office (TODAY) Complete LLC (LLC) register。Foreign-funded state-owned enterprises’ shareholding exceeds 33% It needs to be approved by the National Development Bureau first.。Register with the State Administration of Taxation for tax purposes，Obtain a taxpayer identification number and open a separate bank account。
second stage：Compilation of application dossier and system audit
write 4 Annual Business Plan and AML Internal Control Procedures。The software system must pass statutory information technology standard certification (MNS ISO/IEC 27001) and national "Cybersecurity Law" security license certification。
The third stage：Submit application and FRC on-site verification
Submit complete dossier to FRC。The FRC is required by law to conduct on-site inspections during audits，Verify that technical infrastructure and physical sites meet standards。
Stage 4：Regulatory review and resolution (3-6 months)
After receiving complete documents，The FRC is legally required to 6 A decision will be made within three months (the chairman has the right to extend 6 months)。If replacement parts are needed，Applicants must be in 30 Make up within 10 working days，Overdue will be considered as not submitted。
The fifth stage：Approved registration and charter renewal
After approval，The company is issued a registration number and entered into the "VASP Comprehensive System"。15 Changes to the company's articles of association and national registration certificate must be completed within 3 working days，and file a copy with the FRC。
7. Anti-Money Laundering “Travel Rule”(Travel Rule) and【Legal Red Line of Technical System】
300Wantugulik Travel Rule trigger threshold：A single transfer amounted to NT$3 million，Initiator and receiver VASP must collect in both directions、Verify and securely transmit the full names of sponsors and beneficiaries、ID number、Wallet address and transaction purpose。
Anti-manipulation mechanism and privacy protection：The system must ensure that buyers and sellers of transactions cannot identify each other。VASPs must establish internal monitoring procedures，Troubleshoot high-frequency anomalies、High volatility and related party “reversal” (5 or more) transactions。The person suspected of committing a crime must be 24 Report to the National Police Headquarters within hours、Directorate General of Intelligence and FRC。
Force two-step verification (2FA)：Before performing a virtual asset transfer or custody management request for a client，VASP systems must enforce two-step verification and check the accuracy of the target wallet address to prevent theft。
Consumer Mandatory Risk Disclosure (Break the rigid exchange)：The customer service agreement must clearly state that virtual currency is not legal tender，No central bank or government endorsement，No deposit insurance or securities investor protection mechanisms apply。When platform assets are insufficient to cover losses, customers face the risk of being unable to recover funds.。
8. [Official Stamp Tax and Comprehensive Operating Budget] for VASP License in Mongolia
| Funding and Expense Categories | Legal requirements and budget baselines (USD/MNT) |
|---|---|
| VASP License Registration National Stamp Duty (core fee) | Carry out legal currency exchange、Cryptocurrency trading、transfer、Hosting services：every business 5000 Wantuglik。 Provide issuance-related financial services (ICO etc.)：1 Yitugrik。 |
| Foreign equity capital requirements and establishment stamp tax | Each foreign shareholder must invest no less than 10million dollars。 Stamp duty agreement for establishment of foreign-invested companies 75Wantuglik (about 220 Dollar)。 |
| Legal agency and local structure establishment | Includes LLC registration、Compliance document drafting、Local corporate bank account opening assistance，The average market price of turnkey agency fees is approximately 20,750 Dollar about。 |
| Annual Statutory Compliance and Chartered Audit Costs | It is compulsory to hire FRC registration and filingChartered Compliance Audit FirmIssue audit report；Purchase Travel Rule Blockchain Analysis and Screening Software；Pay VASP professional association dues。High annual expenses。 |
9. Hong Kong Huitong's Mongolian VASP license legal agency service
LLC corporate establishment and physical office implementation
Handle Mongolian LLC company registration and tax registration。Assistance with leasing physical offices that meet FRC on-site verification standards，Comply with legal requirements (Fit & Proper) Reviewed by independent directors。
Core legal documents and system construction
write 4 Annual business development plan and customer agreement (including mandatory disclaimer)。Prepare AML/CFT internal control procedures in compliance with FATF standards、Travel Rule response and business liquidation emergency plan。
FRC application and chartered audit docking
Agent submits case file to FRC and responds 30 Deadline for written inquiry。Assistance in opening a segregated account at a local compliant credit institution，Connecting FRC Chartered External Audit Agency and IT Security Certification and Certification Agency。
10. Mongolia VASP Digital Currency License Core Legal Questions and Answers (FAQ)
Statutory business is governed by the Virtual Asset Service Provider Law (promulgated in 2021) and the Financial Supervisory Commission (FRC) Regulatory supervision。Mongolia fully complies with 40 FATF recommendations，Anti-money laundering supervision is seamlessly integrated with international standards。
Article 6.1 of the bill covers five core businesses：Legal currency and virtual asset exchange、Cryptocurrency trading、Asset transfer、Asset custody and administration，and financial services participating in public offerings or sales (ICO/IEO)。
The core business share capital shall not be less than MNT 400 million。To apply for multiple services, capital must be added based on business。The source of funds must be legal currency，Loans are strictly prohibited。The minimum capital contribution of each foreign investor in a foreign-invested enterprise must reach US$100,000.。
Total virtual assets held and administered by VASP，The legal maximum shall not exceed its own capital (Capital Equity) 100 times。Institutions must measure capital adequacy ratios on a quarterly basis to prevent systemic risks。
Absolutely not。Applicants must be legal entities legally registered in Mongolia。Owned capital calculations explicitly exclude overseas assets。When applying for registration, proof of actual office address in Mongolia must be provided for FRC on-site verification。
board of directors at least 5 members (including 2 independent directors)。Executive management and actual controllers must have financial/legal/IT professional backgrounds；No record of overdue loans；Absolutely exclude money laundering、Persons convicted of economic crimes such as terrorist financing。
An internal audit department must be established、Information Technology Department、Customer service department，and the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Supervision and Implementation Department。Offering assets to the public also requires the establishment of an offering and trading business department。
A four-year business development plan must be submitted；Proof of legal source of funds；Exclusive bank account opening agreement for segregating client funds；Audited financial statements for the past three years；AML/CFT Risk Assessment Report；IT Security Instructions and Termination and Liquidation Plan。
After FRC receives complete application materials that meet statutory requirements，will be in 6 A decision will be made within months (the chairman has the power to extend up to 6 months)。If replacement parts are needed，Applicants must be in 30 Replenish it within working days。
The system must be certified to statutory information technology standards。A single transfer amounted to NT$3 million，Collection of transfer originator and beneficiary details must be mandatory in both directions。Mandatory two-step verification (2FA) before transferring and hosting assets。
yes。Licensed institutions must submit to the FRC every year a legally qualified (specifically registered by the FRC)、Annual financial report issued by an independent auditing agency with a capital of NT$30 million and a resident auditor)。
Unauthorized misappropriation of customer legal currency or virtual assets is strictly prohibited；Not maintained 100 capital adequacy ratio within；Failure to perform anti-money laundering monitoring reporting obligations。Triggering the red line FRC will limit、Suspension of business until compulsory deregistration。
