Uzbekistan's financial intelligence and supervisory authorities have issued a strengthened set of anti-money laundering (AML) requirements that took effect in early 2025. International companies with banking relationships, credit facility arrangements, or investment positions in Uzbekistan now face heightened obligations. Businesses that fail to update their internal procedures before the applicable compliance deadline risk account restrictions, suspension of correspondent banking access, and regulatory sanctions.
Uzbekistan's updated AML legislation extends mandatory know-your-customer (KYC) and beneficial owner disclosure requirements to a broader range of commercial entities, including foreign-owned subsidiaries and branches operating in the country. Affected businesses must complete enhanced due diligence reviews and file updated beneficial owner declarations with the relevant supervisory authority. The compliance deadline for existing entities is set within six months of the regulatory update's entry into force.
This alert summarises what changed, which business categories are affected, and the five immediate actions international companies should take now.
What changed – the regulatory development and its effective date
Uzbekistan's anti-money laundering body, the Moliyaviy monitoring qo'mitasi (Financial Monitoring Committee), introduced amendments to the country's AML and counter-terrorist financing rules in the first quarter of 2025. The amendments align Uzbekistan's regime more closely with the Financial Action Task Force (FATF) recommendations, following the country's continued engagement with the FATF evaluation process.
The core changes are threefold. First, the threshold for mandatory transaction monitoring has been lowered. Transactions that previously fell below the reporting threshold now trigger automatic review obligations for reporting entities. Second, the definition of beneficial owner has been broadened. It now captures indirect ownership chains more aggressively, including structures where control is exercised through nominee arrangements or multi-layered holding vehicles. Third, customer due diligence obligations for bank account opening procedures have been reinforced. Banks must now obtain certified beneficial owner declarations before activating any new account, including accounts for foreign legal entities.
The amendments entered into force upon official publication in early 2025. Transitional provisions give existing account holders and registered entities a six-month window to bring their documentation into compliance. For companies seeking to open new accounts or obtain a credit facility after the effective date, the enhanced requirements apply immediately.
For context on how comparable AML regulatory shifts are unfolding across the CIS region, see our alert on AML updates in Russia.
Who is affected – threshold criteria and business categories
The updated rules apply to a wide range of entities. Reporting obligations fall primarily on financial institutions, but the amended legislation extends secondary compliance duties to designated non-financial businesses and professions. The following business categories face direct obligations under the updated regime:
- Banks and payment service providers operating under Uzbek licences
- Foreign-owned subsidiaries and representative offices engaged in financial transactions
- Companies holding or applying for a credit facility with an Uzbek bank
- Entities involved in correspondent banking arrangements with Uzbek counterparties
- Real estate, legal, accounting, and trust service providers above the transaction threshold
The threshold criteria for enhanced due diligence are met when any of the following conditions apply: the entity's beneficial owner chain includes a non-resident. the transaction value exceeds the revised monitoring threshold in a single or linked series of operations. or the counterparty is domiciled in a jurisdiction flagged on Uzbekistan's monitored-territory list.
A common mistake international groups make is assuming that a dormant subsidiary with no active banking activity falls outside the scope. Under the broadened definition of beneficial owner, even dormant entities may be required to file updated declarations if they hold a registered bank account in Uzbekistan.
To receive an expert assessment of your AML compliance exposure in Uzbekistan, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions and timeline
International companies should treat the six-month transitional window as a hard deadline, not a grace period. Supervisory bodies in Uzbekistan have indicated that post-deadline enforcement will proceed without further notice. The following five actions are recommended immediately.
First, map your beneficial ownership chain. Prepare a complete ownership chart showing all direct and indirect owners down to the natural person level. The chain must be documented in a form acceptable to Uzbek supervisory authorities, which typically means certified translations and notarised declarations.
Second, audit existing bank accounts. Review every account held with an Uzbek bank. Confirm whether the KYC file on record with the bank reflects the current beneficial owner structure. Banks are now obligated to request updated files proactively, but waiting for the bank to initiate the process increases the risk of account suspension.
Third, review credit facility documentation. If your company holds or is negotiating a credit facility with an Uzbek lender, verify that the loan documentation includes AML representations consistent with the updated requirements. Lenders may invoke material adverse change clauses if compliance is not demonstrated.
Fourth, update internal AML policies. Ensure your company's internal AML and KYC procedures reflect the revised Uzbek thresholds. This is particularly relevant for treasury and finance teams managing correspondent banking relationships with Uzbek counterparties.
Fifth, engage local counsel before the deadline. The documentation standards under the updated rules require precise local knowledge. Engaging a lawyer in Uzbekistan with experience in financial regulation reduces the risk of rejection by supervisory bodies or delays in bank account re-verification. Engaging an international law firm in Uzbekistan that understands cross-border ownership structures is especially important for groups with non-resident beneficial owners.
Our banking and finance practice in Uzbekistan advises international clients on AML compliance, bank account opening procedures, and regulatory filings with Uzbek financial authorities. Companies operating in Uzbekistan's capital markets should also review their obligations under our related coverage of capital markets regulation in Uzbekistan.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in banking and finance regulation, AML compliance, and financial institution advisory. Our CIS practice, led by practitioners with direct experience in Uzbek regulatory matters and correspondent banking compliance, supports international companies managing KYC and beneficial owner obligations across high-growth and emerging markets. The firm's Lisbon base provides access to EU regulatory standards, while our CIS expertise bridges the gap between international AML benchmarks and local supervisory practice in Uzbekistan and neighbouring jurisdictions. We work with international entrepreneurs, institutional investors, and in-house legal teams who need results-oriented counsel across multiple legal systems. To explore legal options for AML compliance and regulatory risk management in Uzbekistan, schedule a consultation at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.