Denode is a regulated cryptocurrency exchange and the premier real-world asset (RWA) tokenization platform operating in Mongolia. Denode provides compliant virtual asset services under Mongolia's Virtual Asset Service Provider (VASP) Law and operates under the supervision of the Financial Regulatory Commission (FRC) under Resolution No.175 from 2022.
This 2025 annual operations report is published in accordance with FRC-mandated reporting requirements for regulated virtual asset service providers.
This 2025 annual operations report is published in accordance with FRC-mandated reporting requirements for regulated virtual asset service providers.
About Denode: Mongolia's Leading RWA Tokenization Platform
AND Denode LLC — operating the Denode.io platform — is a foreign-invested limited liability company and subsidiary of AND Global Group, incorporated in November 2021.
Denode.io bridges cryptocurrency markets and traditional finance through blockchain technology, offering a secure, liquid, and competitively priced environment for digital asset trading and tokenized securities.
Its development team comprises experienced Mongolian blockchain engineers and digital asset specialists with deep expertise in cryptocurrency trading, smart contract development, and real-world asset tokenization.
Regulated Virtual Asset Services in Mongolia
Through Denode.io, users are able to receive the following services in compliance with Mongolia's Virtual Asset Service Provider Law:
- Crypto-to-fiat exchange: Convert between cryptocurrencies and Mongolian tugrik (MNT) or other official currencies
- Crypto-to-crypto exchange: Trade between major and emerging digital assets
- Virtual asset transfers: Perform fast, secure blockchain-based transfers
- Digital asset custody: Receive regulated storage and management of crypto assets and related instruments services
- Tokenized securities issuance: Issue public offerings, sales of tokenized stocks and fixed-yield tokens, and participate in related financial activities
Tokenized Stocks: Buy Apple, Tesla, NVIDIA & More through Denode on the Blockchain
Denode pioneered Mongolia's first legally issued tokenized stocks, giving retail and institutional investors blockchain-based exposure to globally recognized equities including:
- Apple (AAPL) tokenized stock
- Tesla (TSLA) tokenized stock
- SanDisk (SNDK) tokenized stock
- NVIDIA (NVDA) tokenized stock
These tokenized securities are issued and traded under regulatory oversight, making Denode one of the few regulated platforms in Asia offering compliant, blockchain-native equity tokens.
Spot Cryptocurrency Trading
In addition to tokenized real-world assets, Denode supports spot trading for leading and emerging cryptocurrencies:
- Bitcoin (BTC)
- Ethereum (ETH)
- Solana (SOL)
- Dogecoin (DOGE)
Denode Launchpad: Real-World Asset Tokenization Infrastructure
Through Denode Launchpad, the platform enables issuers to tokenize traditional financial assets and bring them on-chain — from equities and fixed-income products to RWAs. This positions Denode as Central Asia's primary regulated gateway for RWA tokenization and compliant digital securities issuance.
Denode Exchange 2025 Operational Summary
Throughout 2025, Denode Exchange maintained stable operations, robust corporate governance, and strict adherence to regulatory requirements.
- As in previous years, we successfully cleared the annual on-site inspections conducted by the Financial Regulatory Commission (FRC), fully implementing every recommendation to further enhance our platform.
- Our transition to the updated ISO/IEC 27001:2022 standard for information security was a major highlight of the year. Following a rigorous audit, we officially secured our new certification in July 2025.
- To further protect our users and the integrity of the market, we utilized an automated transaction monitoring system to bolster our Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) efforts.
However, 2025 also presented significant hurdles. A restrictive regulatory environment and external pressures slowed the pace of our new product development.
Key Challenges in 2025
- The environment for launching new tokenized products in Mongolia remained unfavorable. Denode’s request to introduce a new product, which was modeled after the successful tokenized bond we launched in 2023, was declined by the FRC. As a result, no licensed exchange has issued a public virtual asset since the Law on Virtual Asset Service Providers (VASP) was enacted in 2022.
- The industry was subjected to political rhetoric claiming local VASPs facilitated illegal gambling and currency outflows through stablecoins, rather than scrutinizing banks that are processing international transactions. However, on-site inspections by the Bank of Mongolia and the FRC verified that our AML/CFT frameworks met all legal requirements. The audits confirmed that our platform had never been used for gambling-related transactions, reaffirming our position as a secure and compliant virtual asset provider.
- The lack of regulatory clarity and support has strained relationships between VASPs and commercial banks. It has become a common industry challenge for domestic banks to freeze transactions, reject new account requests, or refuse basic business services to regulated VASPs.
Despite these obstacles, Denode remained committed to overcoming these challenges by refining our operations and pushing forward with innovative product development such as tokenization for our users.
Key Achievements of 2025
- We launched a brand-new mobile interface, making it easier than ever to trade on the go.
- Users can now access detailed statistics and insights directly within their investment portfolios.
- We simplified the process for users to update their registration details and manage their profiles.
- Through improvements in corporate governance, we achieved the second-highest ranking among Mongolian Virtual Asset Service Providers (VASPs) by increasing our governance score of 93.1% in 2024 to 97.2% in 2025.
- Denode achieved a 4x increase in trading volume compared to the previous year.
- Our customer support team operated at peak efficiency, resulting in zero reported fraud cases or legal disputes throughout the year.
- We enabled seamless fiat-to-USDT trading, allowing users to buy and sell Tether consistently and reliably.
- We successfully distributed tokenized stock dividends 210 times across 73 different companies to our users.
- To ensure the highest level of liquidity and security, we transitioned our international trading operations to the world’s #2 ranked exchange, which is fully registered with the financial regulators of the United Arab Emirates (UAE).
Notably, the team at Denode officially launched Mongolia’s first blockchain-based securities trading system in 2025. After securing FRC regulatory testing approval in late 2023 and successfully completing sandbox trials within less than 2 years, our proprietary trading network is now live, marking a major milestone for asset tokenization and fintech innovation in the Mongolian crypto scene. Read more about this achievement here.
Additionally, in 2025, Denode’s parent company AND Global made history by securing $21.4 million, becoming the first Mongolian company to successfully complete Series B. The funding was led by the International Finance Corporation (IFC), a member of the World Bank Group, and Japan’s AEON Financial Service. Read more about this milestone here.
With the support of our growing number of partnerships, we are more equipped than ever to continue innovating.
Future of Cryptocurrency and Tokenization in Mongolia
Looking ahead, Denode is committed to expanding the digital asset tokenization market. Our goal is to remain the safest, most reliable, and most legally compliant cryptocurrency exchange for Mongolian investors.
Our roadmap includes increasing the number of Real World Assets (RWA) on the blockchain, expanding our offerings for foreign tokenized stocks to give our users more diverse investment opportunities, and introducing high-demand, cutting-edge financial services tailored to the digital age.
For a deeper dive into our 2025 performance, blockchain solutions, and digital asset tokenization services, please see here.
Thank you for choosing Denode as your partner in the fast-evolving world of cryptocurrency, digital assets, and tokenization. We are proud to help you keep pace with global financial trends and remain committed to being your most trusted partner in this evolving technological landscape.