Russia's first comprehensive legal framework for cryptocurrency trading, custody, and cross-border settlements came into effect on September 1st. The new regulations bring these activities under the supervision of the Russian Central Bank. Both retail investors and qualified investors can participate in transactions through regulated intermediaries, but the entry requirements and quotas differ for each group.

Retail investors set an annual purchase limit

Individuals who are not recognized as qualified investors can purchase compliant cryptocurrencies up to 300,000 rubles per year through each intermediary institution after passing the suitability test. Qualified investors also need to complete the test, but they are not subject to this annual purchase limit.

The Russian Central Bank previously proposed that Bitcoin, Ethereum, and USDT could be included in the scope of regulated transactions. As for the final currencies that will be open to retail investors, it will depend on criteria set by regulators such as liquidity, trading volume, and price history, as well as the products actually offered by licensed institutions.

Exchanges and custodian institutions to be incorporated into the licensed system

This law establishes specialized roles for crypto exchanges and digital custodian institutions. Exchanges are responsible for matching buyers and sellers, while digital custodian institutions are responsible for recording the ownership of cryptocurrencies and other digital assets. Brokers, asset management companies, and organized trading platforms may also participate in related transaction arrangements.

According to the rules disclosed during the legislative process, institutions providing encrypted transaction services are required to be listed in a specialized register, have at least 15 million rubles of own capital, and join recognized self-regulatory organizations of the financial market. The Central Bank of Russia will maintain a register of regulated participants and establish operational requirements for exchanges, custodian institutions, and digital currency accounts.

Digital custody institutions are subject to separate capital standards. A draft published in July indicates that the minimum capital requirements range from 50 million to 250 million rubles, depending on the specific services they provide, including whether they access open distributed ledgers and whether they undertake post-trade settlement functions.

Cross-border settlement finds a legal path

The new framework maintains the prohibition within Russia on using cryptocurrencies for paying for ordinary goods and services, which means that digital currencies are still not considered a tool for domestic commercial payments. However, in foreign trade, exporters and importers can use cryptocurrencies for cross-border settlements under the new regulations, with no upper limit on the amount.

Enterprises can either complete compliant transactions through intermediaries or directly use different wallets and digital currencies for settlement. The new regulations effectively formalize the cross-border crypto settlement pathways that were previously piloted into the legal framework.

In addition, Russian residents can still conduct cryptocurrency transactions overseas through bank accounts abroad. If assets are recorded abroad, the relevant holdings must be declared to the Russian tax authorities. The law also allows investors to exchange cryptocurrencies for securities and digital financial instruments issued under Russian law, and these requirements also apply to stablecoins based overseas.

Implementation of some supporting rules postponed

Although the core provisions came into effect on September 1st, some of the content will be implemented in phases. Rules regarding certain transfer restrictions and the operations of non-resident digital custodian institutions will be put into effect on July 1, 2027; technical provisions concerning the issuance and circulation of digital financial assets, as well as nominal holders and custody arrangements, are scheduled to take effect on September 1, 2027.

Major financial institutions in Russia have begun preparing services around the new framework. The Savings Bank of the Russian Federation plans to complete the construction of the encrypted transaction infrastructure and digital custody system by December 1st, with the service scope expected to cover transactions, custody, settlement, and depository services. Alpha Bank has also tested encrypted transaction services for a small group of qualified investors through its brokerage application.