DataGuidance confirmed, on 2 March 2018, with Kymbat Ibakova, Senior Associate at Lorenz Law Firm, that the National Bank of Kyrgyzstan ('NBKR') had drafted amendments ('the Draft Amendments') to the Regulation on Electronic Money in the Kyrgyz Republic ('the Regulation'), as adopted by the Decree of the Board of the National Bank of the Kyrgyz Republic of 30 March 2016 No. 15/6. In particular, the Draft Amendments to the Regulation relate to obligations to identify parties to transactions involving digital wallets.

Ibakova outlined, "The main reason for the introduction of the Draft Amendments to the Regulation are the risks associated with Kyrgyz mobile operators launching new systems allowing mobile users to use their balance to top up a digital wallet and pay for communication and other services via applications provided by such mobile operators. Pursuant to paragraph 8 of the Draft Amendments, in the event of cross-border transfer of electronic funds, the holder of a digital wallet must be identified. We assume that such identification should be done in accordance with the identification procedure for counteracting legalisation (laundering) of criminal incomes and financing of terrorist or extremist activities, including through the identification of the relevant information on the basis of documents submitted by an individual or legal entity or duly notarised copies of such documents. As a rule, identification of a party in case of an electronic payment or transfer should be executed by a bank or other financial institution, through the use of questionnaires provided to the parties to the transfer."

You can read the Draft Amendments, only available in Russian here, and in Kyrgyz here.