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title: "Russia Crypto Regulation Monitor | cryptoassets.gi"
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description: "Russia crypto asset regulation: 8 categories, 61 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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# Russia Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed in transition overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/russia/), [World Payments](https://payments.gi/jurisdictions/russia/)

Last updated 2026-10-25 · 8 categories · 61 sourced
findings · 76 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot ↗](/reports/?type=copilot&j=RUSSIA)[Build Report](/reports/?j=RUSSIA)[Compare](/compare/?j=RUSSIA)

Framework posture In transition 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority 2026 Russian cryptocurrency circulation law Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2027-Q1 Rosfinmonitoring RUB 60,000 crypto-transaction reporting threshold

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 3 Open gaps 61 Findings

23 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 25 October 2026

#### Lead Signal

Russia's crypto-regulatory architecture moved from framework to live operation this period. The licensing gateway created under Federal Law No. 282-FZ opened its registration window on 5 October 2026, with the Bank of Russia processing applications for exchanges, brokers, asset managers, digital depositories and exchangers; decisions are reported to follow within 60 working days of application. Seventeen firms had registered by 22 October 2026, including the state-controlled banks Sberbank and VTB, giving the regime an immediate bank-led character rather than a native-crypto-industry one. A minimum capital figure applies to licensees, though the exact amount is disputed between secondary sources, with one reporting RUB50 million and another RUB15 million; no primary Bank of Russia text has resolved which figure governs.

#### Other Developments

Cross-border settlement liberalisation sits alongside the licensing rollout. Authorised Russian exporters and importers are now permitted to use crypto and digital financial assets for cross-border trade settlement without transaction limits, a permission confirmed in reporting from mid-October 2026 and available whether the counterparty uses an intermediary or any wallet type directly. This liberalisation is reported as functioning in parallel with, not instead of, the new licensing gateway, and is read in the surrounding coverage as oriented toward settlement channels that do not depend on Western-linked correspondent banking. Stablecoin policy took a different direction: the Bank of Russia declined on 22 September 2026 to draft standalone legislation for a ruble-pegged stablecoin, with the chairman of the Moscow Exchange Supervisory Board citing an absence of demand from foreign trade partners for such an instrument. Fiat-pegged tokens accordingly remain governed under the existing digital-financial-asset framework established by Federal Law No. 259-FZ rather than gaining a dedicated regime. A peer-to-peer ban is also now on the books: the Bank of Russia has announced that direct peer-to-peer digital-asset transactions will be prohibited from 1 July 2027, a measure reported as designed to channel trading activity toward the newly licensed intermediaries rather than informal counterparty-to-counterparty transfers. Mining-sector reporting continues under Federal Law No. 221-FZ, which requires registered miners to report the currency mined and an address identifier to the Federal Tax Service by the 20th of the following month; this obligation is standing and was not altered this period.

#### Cross-Monitor Connections

The commercial dimension of this period's licensing rollout is notable: Sberbank and VTB, Russia's two largest state-controlled banks, moved first and fastest into the newly licensed crypto space. VTB settled its first corporate stablecoin trades on 6 October 2026 through a newly established digital depository, while Sberbank joined the Bank of Russia's crypto-exchange register on 12 October 2026. Both institutions are reported to be targeting retail-facing crypto-trading launches before the end of the year. This concentration of early licensed activity in state-controlled banking champions, rather than independent exchanges, is a structural feature of how the regime is taking shape, and it connects directly to the broader sanctions-posture questions tracked elsewhere: a licensing and settlement architecture built around state banks and oriented toward sanctions-resilient settlement rails is a different kind of development than a consumer-facing crypto market opening on its own terms.

#### Outlook

The most consequential near-term date is 1 July 2027, when the peer-to-peer trading ban takes effect, a point by which licensed intermediary capacity will need to have absorbed whatever volume currently moves through informal channels; current informal P2P volume is reported as substantial, and whether licensed capacity can absorb it by that date is untested. A second date worth tracking is September 2028, the full-compliance deadline under which platforms currently on the existing OIS registry must complete full licensing and capital compliance; grey-market exchangers are expected to remain active in the interim. Nearer-term, Sberbank's and VTB's targeted retail-trading launches, reported for the November-December 2026 window, will be the first real test of whether the state-bank-led licensing model translates into consumer-facing products at scale.

2 earlier updates not shown here.

###### Standing brief · as of 2 September 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Russia's comprehensive cryptocurrency circulation law entered into force on 1 September 2026, establishing for the first time a registry-based licensing regime for cryptocurrency exchanges and digital depositories (CLM-RU-001). The same law grants market participants a transition period running through 1 July 2027 to obtain licences and achieve full compliance, with a reported grace period around March 2027 for existing exchanges to complete registry entry (CLM-RU-002). This is the single largest structural change to Russia's crypto regime tracked this cycle, converting what had previously been a fragmented patchwork of mining registration, digital-financial-asset classification and ad hoc sanctions-workaround policy into a unified licensing perimeter overseen by the Bank of Russia. Notably, the anchor claim describing the law's entry into force is held at this station pending independent verification against the primary gazetted statute text -- a Challenger-flagged requirement, notwithstanding an existing Tier-1 Bank of Russia press citation corroborating the same fact (CLM-RU-001). Readers should treat the licensing perimeter's exact contours, and particularly the digital-depository capital-requirement rules still open for consultation, as provisional pending that primary-source confirmation.

#### Other Developments

The new law operates alongside, rather than in place of, Russia's pre-existing crypto architecture. Mining remains legalized and separately registered: legal entities and individual entrepreneurs engaging in cryptocurrency mining have been required to register with the Ministry of Digital Development since 1 November 2024 (CLM-RU-003), with private citizens under government electricity-use limits exempted from that requirement (CLM-RU-005). Regional mining prohibitions continue to expand piecemeal and now reach the capital region: a 2024 decree bans mining and mining-pool participation across 10 regions through March 2031 (CLM-RU-012), while Government Decree No. 936 extends that prohibition to Moscow, the Moscow region and part of Kursk through the end of 2032 (CLM-RU-013) -- the newest and most operationally significant expansion tracked this cycle. A further, still-unconfirmed extension would add year-round restrictions in southern Irkutsk and most of Buryatia and Zabaykalsky Krai (CLM-RU-014).

On classification, Federal Law No. 259-FZ continues to treat digital financial assets as an investment instrument distinct from cryptocurrency (CLM-RU-007), while Russian statute still has no defined legal category for "stablecoin" -- stablecoin-like instruments may only be issued as DFAs, usable for cross-border but not domestic settlement (CLM-RU-008). The new law folds foreign stablecoins into the general cryptocurrency compliance perimeter (CLM-RU-009, restated within the stablecoin-regime lens at CLM-RU-018), even as a bespoke domestic ruble-stablecoin framework remains only at consultation stage: the Bank of Russia's 2026 consultation paper raises open questions on par redemption, redemption periods, reserve adequacy and issuer resilience (CLM-RU-016), and separately proposes preserving the existing ban on using DFAs or stablecoins for resident-to-resident domestic settlement to avoid fragmenting the payments market (CLM-RU-017). The digital ruble, meanwhile, began its large-scale national rollout the same day the new law took effect, formally classified as a third, sovereign form of the national currency distinct from privately issued tokens or DFAs (CLM-RU-010, CLM-RU-019).

Retail-facing protections also took binding effect on 1 September: non-qualified investors face an annual purchase cap of ₽300,000 per intermediary, contingent on passing a mandatory knowledge and risk test, while qualified investors face no cap but must still test (CLM-RU-020); retail purchases are further restricted to the "most liquid" cryptocurrencies, though the Bank of Russia has not yet published which assets qualify (CLM-RU-021). The law also guarantees judicial protection for digital-currency holders regardless of prior declaration status (CLM-RU-023) and bans advertising or promotion of cryptocurrency for payments (CLM-RU-024), while preserving the Bank of Russia's standing characterization of cryptoassets as a high-risk instrument with no identifiable issuer or jurisdictional guarantee (CLM-RU-022).

On tax, the 2024 Tax Code amendments (effective 2025) continue to tax crypto mining and transaction income at 13% up to ₽2.4 million annually and 15% above that threshold, with crypto transactions exempt from VAT (CLM-RU-025, CLM-RU-026), and monthly reporting of mined cryptocurrency required by the 20th of the following month (CLM-RU-028). This module's confidence rating was downgraded this cycle from Confirmed to Probable following Challenger review, which found the prior Confirmed rating inconsistent with a run that retrieved zero Tier-1-to-3 primary tax sources; a Federal Tax Service or Ministry of Finance document is still needed to restore higher confidence.

#### Cross-Monitor Connections

Two overlap flags carry forward from this cycle. On the financial-integrity side, OFAC's designation of a network including Old Vector, A7 LLC and subsidiaries tied to the shuttered Garantex exchange and the A7A5 ruble-backed stablecoin (CLM-RU-033), together with the EU's 20th sanctions package banning EU persons from transacting with Russian and Belarusian crypto and DeFi platforms -- including the digital ruble CBDC and the RUBx stablecoin (CLM-RU-034) -- sit directly alongside Russia's own law, which affirmatively enables unlimited cross-border crypto settlement for foreign trade via any wallet or intermediary (CLM-RU-030) and traces to a 2024 Bank of Russia experimental legal regime explicitly linked to sanctions-circumvention policy goals (CLM-RU-031). The A7A5 ecosystem alone is reported to have processed an estimated $119.7 billion to date, functioning as a settlement rail bridging sanctioned Russian businesses into the global financial system (CLM-RU-035). This is an acute domestic-versus-international divergence: what Russian law affirmatively permits, OFAC and the EU are independently and simultaneously moving to prohibit for anyone with a US or EU nexus. On the world-payments side, the digital ruble's rollout and the stablecoin consultation's redemption and reserve-adequacy questions (CLM-RU-016, CLM-RU-017, CLM-RU-019) carry payments-rail implications worth tracking alongside that monitor's own settlement-infrastructure coverage.

#### Outlook

The next fixed points on the calendar are the exchange registry-entry grace period expiring around March 2027 and the full licence-compliance deadline of 1 July 2027 -- both will test whether the transition period announced alongside the new law converts into an actual compliance base among existing market participants. The Bank of Russia's stablecoin consultation, whose comment window closed the same day the new law took effect, will determine whether a dedicated ruble-stablecoin statute follows with defined redemption and reserve standards. Regional mining prohibitions remain a moving target, now reaching Moscow itself through 2032, and the "most liquid cryptocurrency" scope for retail purchases remains an open implementing-regulation gap. Most consequentially, the widening gap between Russia's sanctions-workaround-enabling domestic settlement law and the escalating OFAC/EU sanctions perimeter around the same infrastructure is likely to keep intensifying rather than resolve, and the anchor licensing claim itself remains provisionally held pending primary-source confirmation of the gazetted statute text.

Read full brief · 1709 words

Key regulatory facts for Russia Regulatory Dimension Russia Standing Position

Jurisdiction Russia (RU)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 61 sourced findings)

Crypto Licensing Russia's comprehensive cryptocurrency circulation law entered into force on 1 September 2026, creating a registry-based licensing regime for exchanges and digital depositories (CLM-RU-001), with a transition period...

Token Classification Federal Law No.

On-Chain Activity Regime The 2024 mining-legalization law legalizes mining nationwide from 1 November 2024, empowering restriction of digital-currency transactions for monetary stability (CLM-RU-011).

Stablecoin Regime Foreign stablecoins are already bound into the cryptocurrency compliance perimeter under the 2026 law (CLM-RU-018, restating CLM-RU-009 within the stablecoin lens).

Primary Instruments Cited 2026 Russian cryptocurrency circulation law, Ministry of Digital Development (Russia), Russian mining registration regime, Russian banks, Банк России

Last Confirmed / Updated 2026-10-25 (76 sources in cumulative register)

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### Russia: C1 Crypto LicensingAmberEnacted in forceModule confidence: Probable▾

Russia's comprehensive cryptocurrency circulation law entered into force on 1 September 2026, creating a registry-based licensing regime for exchanges and digital depositories (CLM-RU-001), with a transition period through 1 July 2027 and a reported ~March 2027 registry-entry grace period (CLM-RU-002). This sits alongside the pre-existing mining-registration regime in force since 1 November 2024 (CLM-RU-003), with an electricity-use exemption for private citizens (CLM-RU-005). Banks are required to refuse transfers to suspected unregistered exchange operators (CLM-RU-006), and the domestic crypto-payments prohibition continues (CLM-RU-004). The anchor claim (CLM-RU-001) is held pending independent verification against the primary gazetted statute text per Challenger flag f-002.

Open gap — crypto-int-1 Exact minimum-capital figure for 282-FZ licensees could not be reconciled from a primary CBR text; two secondary sources diverge (RUB50m vs RUB15m). no under-indexing note recorded

Horizon · 2027-07-01 (± six months) 282-FZ full licensing and enforcement regime for crypto-market participants Adopted, not yet in force · Tier 4 source

Horizon · 2028-09 (± a year) 282-FZ full compliance deadline for OIS-registry platforms Adopted, not yet in force · Tier 4 source

Horizon · 2027-07-01 (± a quarter) Direct P2P crypto-trading ban Adopted · Tier 3 source

#### Crypto Licensing

Russia's comprehensive cryptocurrency circulation law entered into force on 1 September 2026, establishing the country's first registry-based licensing regime for cryptocurrency exchanges and digital depositories (CLM-RU-001). This is a foundational shift: previously, Russian crypto policy consisted of a payments prohibition, a separate digital-financial-asset framework, and a standalone mining-registration regime, with no unified licensing perimeter for trading venues or custodial infrastructure. The new law changes that, though its anchor claim -- the fact of the law's entry into force and the shape of the registry-based regime it creates -- remains held at this station pending independent verification against the primary gazetted statute text, per a Challenger escalation requiring confirmation beyond the existing Tier-1 Bank of Russia press citation that corroborates the same fact.

The law grants market participants a transition period running through 1 July 2027 to obtain licences and reach full compliance, with a reported grace period around March 2027 for existing exchanges to complete registry entry (CLM-RU-002). That two-stage runway -- registry entry first, full licence compliance second -- means the practical compliance bar for exchanges and digital depositories will not be fully tested for close to a year after the law's nominal effective date.

The new licensing perimeter sits alongside, rather than replacing, Russia's pre-existing mining-registration regime. Legal entities and individual entrepreneurs engaging in cryptocurrency mining have been required to register with the Ministry of Digital Development since 1 November 2024 (CLM-RU-003), with private citizens who stay within government-set electricity-use limits exempted from that requirement, while businesses and entrepreneurs must still register (CLM-RU-005). The banking system has been enlisted to help enforce the registry: Russian banks are required to refuse transfers where an unauthorized or unregistered entity is suspected of operating a cryptocurrency exchange (CLM-RU-006), effectively extending the registry requirement's reach through payment-rail gatekeeping. The law also continues to prohibit the use of cryptocurrencies for payments within Russia (CLM-RU-004), preserving the long-standing separation between crypto as an investable/tradeable asset class and crypto as a means of domestic payment.

#### Outlook

Two dates now anchor the forward calendar: the exchange registry-entry grace period expiring around March 2027, and the full licence-compliance deadline of 1 July 2027. Both will determine whether the transition period converts into an actual compliance base among existing market participants, or whether enforcement gaps persist into the new regime's second year. Separately, the Bank of Russia's draft digital-depository capital-requirement rules, opened for consultation in July 2026, remain unresolved as implementing regulation under the new licensing perimeter -- their final form will materially affect how burdensome the new custodial-licensing track actually is in practice. Most immediately, though, the module's own anchor claim remains provisionally held pending primary-source confirmation of the gazetted statute text; that confirmation, once obtained, is likely to either validate the current amber rating or surface material drafting detail not yet visible in secondary reporting.

Read full sub-brief · 471 words Periodic update · new data 2026-10-25

#### Crypto Licensing

Federal Law No. 282-FZ now supplies Russia's first comprehensive licensing gateway for crypto-asset businesses, administered by the Bank of Russia. The registration window opened on 5 October 2026, covering exchanges, brokers, asset managers, digital depositories and exchangers, with reported decision timelines of up to 60 working days from application. By 22 October 2026, seventeen firms had registered, a list headed by the state-controlled banks Sberbank and VTB rather than independent crypto-native firms, giving the early regime a distinctly bank-led character. A minimum capital requirement attaches to licensees, but the figure is disputed across the secondary reporting reviewed: one source states RUB50 million, another RUB15 million, and no primary Bank of Russia register text has been retrieved to resolve the discrepancy. The regime is less than a month into live operation, so no track record yet exists on how applications are actually being processed or refused. A further compliance horizon sits well beyond this period: platforms currently on the existing OIS registry have, per current reporting, until around September 2028 to achieve full licensing and capital compliance, with grey-market exchangers expected to persist in the meantime. Alongside the new licensing gateway, the Bank of Russia has announced a ban on direct peer-to-peer digital-asset transactions taking effect from 1 July 2027, a measure explicitly aimed at pushing activity toward the newly licensed intermediaries rather than informal counterparty transfers, reinforcing the gateway's role as the intended channel for future crypto activity in Russia.

#### Outlook

Watch for the resolution of the minimum-capital discrepancy once a primary Bank of Russia text becomes available, and for how application-decision rates develop as the 60-working-day review windows for the first wave of applicants begin to close. The 1 July 2027 peer-to-peer ban and the September 2028 full-compliance deadline for OIS-registry platforms are the two dated markers against which the licensing regime's practical reach should be measured.

2 earlier distinct update(s) Periodic update · new data 2026-10-18

#### Crypto Licensing

Federal Law No. 282-FZ's core licensing provisions entered into force on 1 September 2026, a date confirmed directly by the Bank of Russia's own press notice covering the State Duma's second and third readings of the law. The provisions now in force include the Special Register mechanism and net-asset minimums applicable to crypto-market participants, giving Russia a comprehensive statutory licensing architecture for the first time. The law's non-resident digital-depository provisions, however, remain pending: full compliance, including the licensing regime applicable to existing exchange-operator participants currently operating on a transitional basis, is not required until 1 July 2027. This creates a mid-transition posture in which a licensing framework exists and partially binds today, while a materially consequential component, governing how non-resident depositories interact with the regime, awaits its own effective date nearly a year out. A separate open question concerns Bill No. 1193493-8, which would create criminal liability for illegal digital-currency mining under a proposed Criminal Code Article 171.6; a State Duma committee recommended the bill for second-reading passage on 18 June 2026, but whether it has since advanced further has not been confirmed this cycle.

#### Outlook

The non-resident digital-depository compliance deadline of 1 July 2027 is the next major date on the licensing horizon and will determine whether existing crypto-exchange operators can continue operating on their current transitional basis or must complete full licensing-regime compliance. Confirmation of Bill No. 1193493-8's legislative progress beyond its 18 June 2026 committee recommendation would also clarify whether criminal liability for illegal mining has been enacted.

Periodic update · new data 2026-10-11

#### Crypto Licensing

Federal Law No. 282-FZ establishes Russia's first comprehensive crypto-market licensing structure, creating five licensed participant classes, exchanges, custodians, brokers, trading venues, and asset managers, under direct supervision of the Bank of Russia. Reported licensing conditions include a minimum capital requirement of RUB 15 million for exchange operators and mandatory membership in a self-regulatory financial-market organisation, though no primary pravo.gov.ru text has been located to confirm the exact statutory article or pinpoint citation; the governing source for these specifics remains commentary rather than the law itself. The regime's commencement is staged: most provisions began from 1 September 2026, while full enforcement, including penalties for unauthorised intermediary operation, is reserved until 1 July 2027. This creates an extended transitional window in which the licensing structure exists in statute but is only partially operative in practice.

Separately, Federal Law No. 221-FZ, already in force since 1 November 2024, requires Russian legal entities and individual entrepreneurs engaging in digital-currency mining to enter Federal Tax Service miner and infrastructure-operator registries. Household miners consuming below 6,000 kWh per month are exempt from registration but remain liable for personal income tax on mined currency; registered miners face monthly tax-reporting obligations. This mining-registration regime is better-sourced than the newer 282-FZ licensing conditions and represents the more mature end of Russia's crypto-licensing architecture.

#### Outlook

The period to 1 July 2027 is the decisive window: that is when 282-FZ's licensing obligations become fully enforceable with penalties attached. Until primary pravo.gov.ru text is located, the precise capital and self-regulatory-organisation conditions for exchange operators should be treated as reported rather than confirmed.

Sources and findings (8)
- T1 · Bank of Russia[2026 Russian cryptocurrency circulation law](https://www.cbr.ru/eng/press/event/?id=32724) — a registry-based licensing regime for crypto exchanges and digital depositories, effective 1 September 2026
- T1 · Bank of Russia[2026 Russian cryptocurrency circulation law](https://www.cbr.ru/eng/press/event/?id=32724) — 1 July 2027 for market participants to obtain licences and achieve compliance, with a reported ~March 2027 grace period for existing exchanges' registry entry
- T4 · CoinDesk[Ministry of Digital Development (Russia)](https://www.coindesk.com/policy/2024/07/30/russia-legalizes-crypto-mining-and-brings-an-experimental-regime) — legal entities and individual entrepreneurs engaging in cryptocurrency mining, effective 1 November 2024
- T1 · Bank of Russia[2026 Russian cryptocurrency circulation law](https://www.cbr.ru/eng/press/event/?id=32724) — the use of cryptocurrencies for payments within Russia
- T4 · CoinDesk[Russian mining registration regime](https://www.coindesk.com/policy/2025/07/07/russia-creates-registry-of-crypto-mining-equipment-to-tighten-oversight) — private citizens who stay within government-set electricity-use limits from mandatory mining registration; businesses and entrepreneurs must still register
- T4 · CoinDesk[Russian banks](https://www.coindesk.com/policy/2026/07/21/russia-s-parliament-passes-crypto-market-law-rules-to-take-effect-sept-1) — transfers where an unauthorized/unregistered entity is suspected of operating a cryptocurrency exchange
- T1[Банк России](https://www.cbr.ru/press/event/?id=32719) — The Bank of Russia has described a transition period running to 1 July 2027 during which market participants must obtain the necessary licences, and identified crypto-exchangers and digital depositaries as the new categories of infrastructure.
- T1[Президент России (kremlin.ru)](http://www.kremlin.ru/acts/bank/50944) — Federal Law 221-FZ of 8 August 2024, in force from 19 August 2024, added digital currency and goods, works and services aimed at organising its circulation to the list of objects that may not be advertised in Russia, closing off untargeted public offering.

### Russia: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾

Federal Law No. 259-FZ classifies DFAs as an investment instrument distinct from cryptocurrency (CLM-RU-007). Russian statute does not define 'stablecoin' as a distinct legal category; stablecoin-like instruments may be issued as DFAs usable cross-border but not domestically (CLM-RU-008). The 2026 law extends compliance requirements to foreign stablecoins (CLM-RU-009). The digital ruble is classified as a third, sovereign form of national currency, distinct from crypto-tokens/DFAs, with large-scale rollout from 1 September 2026 (CLM-RU-010).

Periodic update · new data 2026-10-18

#### Token Classification

On 22 September 2026 the Bank of Russia announced that it would not pursue a dedicated legal status or category for stablecoins, opting instead to retain fiat-referenced tokens within the existing legal framework governing controlled digital financial assets (CFAs) under Federal Law No. 259-FZ. This is a regulatory policy decision rather than a legislative act: no new statute was passed, and no bespoke stablecoin-specific statutory test has been created. The practical effect is that any Russia-domiciled or Russia-facing stablecoin arrangement continues to be classified and regulated under the general CFA rules that apply to digital financial assets more broadly, with classification resting on the Bank of Russia's administrative characterisation of a given instrument rather than on a codified, stablecoin-specific legal definition.

#### Outlook

Whether the Bank of Russia's 22 September 2026 decision forecloses a future dedicated stablecoin bill entirely, or merely defers one, remains an open question; no subsequent legislative proposal introducing bespoke stablecoin treatment has been identified as of this cycle. Continued reliance on the CFA framework means that any change to the classification treatment of fiat-referenced tokens would likely need to proceed through amendment of 259-FZ itself rather than through a standalone instrument.

Periodic update · new data 2026-10-11

#### Token Classification

Russia's domestic token-classification approach continues to treat digital currency as property rather than legal tender, a position that predates this cycle and remains stable. The cycle's material development concerns a single token: A7A5, a ruble-pegged stablecoin, which the Bank of Russia recognised in September 2025 as a digital financial asset classified as a foreign digital right, a status permitting its use specifically in cross-border trade settlement. A7A5 is issued by Old Vector, an entity registered in Kyrgyzstan, and is backed 1:1 by rubles held at Promsvyazbank, a sanctioned Russian state bank, with transaction processing run through Promsvyazbank's Tokeon platform.

This classification sits awkwardly against the module's standard stablecoin and e-money taxonomy: A7A5 is neither a conventional e-money instrument nor a dedicated-statute stablecoin, but an ad hoc foreign-digital-right designation applied to a specific token for a specific cross-border purpose. That bespoke classification, rather than a generalised statutory category, is itself the notable feature: Russia has not legislated a general stablecoin framework, and A7A5's status derives from a Bank of Russia recognition decision rather than from legislation of general application.

#### Outlook

Whether Russia extends the foreign-digital-right classification to additional tokens, or instead moves toward a dedicated stablecoin statute, is the open question for this module. No dedicated stablecoin-issuance statute currently exists, and A7A5's classification should be read as a single-token recognition rather than as the opening of a general category.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-10-25

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### Russia: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾

The 2024 mining-legalization law legalizes mining nationwide from 1 November 2024, empowering restriction of digital-currency transactions for monetary stability (CLM-RU-011). Regional bans continue expanding: 10 regions through March 2031 (CLM-RU-012), and Moscow/Moscow region/part of Kursk through 31 December 2032 under Decree No. 936 (CLM-RU-013). A further, Probable-confidence extension to southern Irkutsk, Buryatia and Zabaykalsky Krai awaits primary-source confirmation (CLM-RU-014). A non-binding Bank of Russia RWA-tokenisation consultation remains open with no enacted rules (CLM-RU-015).

Periodic update · new data 2026-10-25

#### On-Chain Activity Regime

Russia's on-chain activity regime continues to run primarily through the mining-reporting obligations established by Federal Law No. 221-FZ. Registered miners are required to report the currency mined, together with an associated address identifier, to the Federal Tax Service by the 20th day of the month following the mining activity. This obligation is standing and was not altered this period; it remains the principal mechanism by which on-chain mining output is made visible to the tax authority, independent of the separate licensing framework now governing exchanges and custodial intermediaries under Federal Law No. 282-FZ. The two regimes operate in parallel: 221-FZ governs the extraction and reporting of mined currency, while 282-FZ governs the exchange, custody and settlement activity that follows. No change to the mining-reporting deadline, the scope of reportable activity, or the designated reporting portal was identified this period.

#### Outlook

The mining-reporting regime under 221-FZ is stable and not presently expected to change. What would be worth tracking is any interaction between this reporting duty and the newly opened 282-FZ licensing gateway, particularly whether miners seeking to convert or custody mined currency through a licensed exchange or depository face any additional reporting bridge between the two regimes.

Periodic update · new data 2026-10-18

#### On-Chain Activity Regime

Russia's on-chain mining regime remains lawful at the national level but continues to accumulate region-specific and grid-specific restrictions. A rule reported around 11 October 2026 would require crypto-mining farms to connect to the electricity grid under Category 4, a lower-priority supply classification that permits grid operators to disconnect mining-farm load during periods of supply shortage. This sits alongside the standing Moscow-region mining prohibition, which continues to apply independently of the new grid-connection rule. The Category 4 requirement has not been independently confirmed against a primary energy-ministry source this cycle and rests on a single secondary report, so it should be treated as a reported development pending further confirmation rather than an established regulatory fact. Taken together, these measures describe a tightening trajectory for mining-specific infrastructure access even though mining itself remains a lawful activity nationally.

#### Outlook

Confirmation of the Category 4 grid-connection requirement via a primary energy-ministry or Bank of Russia source would clarify whether this is now a binding national rule or a more limited regional measure. The interaction between the Moscow-region ban and the reported grid-priority rule, whether they apply cumulatively or address different aspects of mining-farm operation, is also not yet settled on the evidence available this cycle.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-10-25

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### Russia: C4 Stablecoin RegimeAmberEnacted in forceModule confidence: Probable▾

Foreign stablecoins are already bound into the cryptocurrency compliance perimeter under the 2026 law (CLM-RU-018, restating CLM-RU-009 within the stablecoin lens). A bespoke domestic ruble-stablecoin regime remains at consultation stage: the Bank of Russia's 2026 paper raises open questions on par redemption, redemption periods, reserve adequacy and issuer resilience (CLM-RU-016), and proposes preserving the existing ban on DFA/stablecoin use for resident-to-resident domestic settlement (CLM-RU-017). The Federal Law on the Digital Ruble (2023) establishes it as the third form of national currency; stablecoin use for international settlement is discussed only as a supplement to the digital ruble (CLM-RU-019).

Periodic update · new data 2026-10-25

#### Stablecoin Regime

Russia does not have, and as of 22 September 2026 does not plan to create, a standalone legal regime for ruble-pegged stablecoins. On that date the Bank of Russia declined to draft dedicated stablecoin legislation, with the chairman of the Moscow Exchange Supervisory Board citing an absence of demand from foreign trade partners for such an instrument as the stated rationale. The practical effect is that fiat-pegged tokens continue to be treated as a sub-type of digital financial asset under the existing framework established by Federal Law No. 259-FZ, rather than receiving reserve-requirement, redemption-right, or issuer-licensing rules specific to stablecoins. No systemic stablecoin-specific prudential regime therefore exists in Russia at this time, a gap that reflects a deliberate regulatory choice rather than an oversight: the regulator considered and declined to legislate. This decision sits alongside, rather than in tension with, the newly opened 282-FZ exchange and depository licensing gateway, through which bank-issued tokens such as the stablecoin trades VTB settled on 6 October 2026 are processed under general digital-financial-asset rules rather than any stablecoin-specific statute.

#### Outlook

Because the September decision was an affirmative decline rather than a deferral, no near-term legislative process toward a dedicated stablecoin statute is presently visible. Any renewed push would most plausibly follow from a change in foreign trade-partner demand, the specific condition the Moscow Exchange Supervisory Board chairman cited as currently absent; that condition is the marker to watch for a reopening of the question.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 11 traced claims · Re-verified 2026-10-25

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### Russia: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾

The 2026 law caps non-qualified investor purchases at ₽300,000/year/intermediary contingent on testing, with qualified investors uncapped but also tested (CLM-RU-020), and restricts retail purchases to the most liquid cryptocurrencies within that cap, scope undefined pending CBR regulation (CLM-RU-021). The Bank of Russia classifies cryptoassets as high-risk with no identifiable issuer/jurisdictional guarantee (CLM-RU-022). The law guarantees judicial protection regardless of prior declaration status (CLM-RU-023) and bans advertising/promotion of crypto for payments (CLM-RU-024).

Open gap — crypto-int-3 No MiCA-Article-75-equivalent custody/segregation statute for client crypto assets was located for Russia. no under-indexing note recorded

#### Consumer Protection

Binding retail-investor protections took effect alongside the rest of the 2026 cryptocurrency circulation law on 1 September 2026, after no consumer-protection framework of this kind previously existed in Russian crypto law. Non-qualified (retail) investors are now capped at ₽300,000 in cryptocurrency purchases per year per intermediary, contingent on passing a mandatory knowledge and risk test; qualified investors face no purchase cap but must also pass the test (CLM-RU-020). Retail investors are further restricted to purchasing only the most liquid cryptocurrencies within that annual cap (CLM-RU-021) -- though which specific assets qualify as "most liquid" has not yet been defined by the Bank of Russia, leaving a live implementing-regulation gap at the heart of the retail-purchase regime on its first day of operation.

Alongside the purchase restrictions, the law guarantees judicial protection for holders of digital currencies regardless of their prior declaration status (CLM-RU-023), extending a legal remedy to holders who may not have previously disclosed their holdings. It also bans banks and other entities from advertising or promoting cryptocurrency for payments (CLM-RU-024), reinforcing the law's separate prohibition on using cryptocurrency for domestic payments by cutting off promotional channels that might otherwise normalize payment use. These binding mechanics sit against the Bank of Russia's standing public characterization of cryptoassets as a high-risk instrument with no identifiable issuer or jurisdictional guarantee, carrying high volatility and sanctions exposure (CLM-RU-022) -- a risk communication that predates the new law but continues to frame the regulator's overall retail-facing posture.

#### Outlook

As of the law's first full day in force, there is no enforcement or dispute-resolution track record to assess how the purchase cap, knowledge test, or judicial-protection guarantee will actually operate in practice. The most immediate open item is the undefined scope of "most liquid" cryptocurrencies for the retail purchase cap -- until the Bank of Russia publishes that list, intermediaries and retail investors alike face uncertainty about which specific assets the ₽300,000 cap actually governs. Enforcement patterns over the coming months, once they begin to emerge, will be the clearest signal of how seriously the new testing and cap regime is being applied.

Read full sub-brief · 351 words Periodic update · new data 2026-10-11

#### Consumer Protection

Federal Law No. 282-FZ introduces a tiered retail-investor protection structure for crypto purchases. Non-qualified retail purchasers are capped at RUB 300,000 per year through a single licensed intermediary and must pass a mandatory knowledge test before purchasing; qualified investors face no such cap. The effective date for these consumer-facing provisions had not yet been reached at the point of this cycle's research cutoff, so the caps and testing requirement should be treated as enacted but not yet in practical effect pending the law's staged commencement.

A material gap remains in this module: no custody or segregation rules for the licensed digital-custody units created under 282-FZ were located this cycle. This leaves open how client assets held by a licensed custodian will be protected in the event of custodian failure or misconduct, a standard consumer-protection question in crypto-asset regimes elsewhere that RU's framework has not yet answered in any sourced text.

#### Outlook

The retail cap and knowledge-test requirement will bear watching as their effective date approaches; separately, custody-and-segregation rules, if and when they are issued, would materially change the consumer-protection picture for RU-licensed custodians and should be treated as the most significant open gap in this module.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (8)
- T1 · Bank of Russia[2026 Russian cryptocurrency circulation law](https://www.cbr.ru/eng/press/event/?id=32724) — non-qualified (retail) investor cryptocurrency purchases at ₽300,000 per year per intermediary, contingent on passing a mandatory knowledge/risk test; qualified investors face no cap but must also test
- T1 · Bank of Russia[2026 Russian cryptocurrency circulation law](https://www.cbr.ru/eng/press/event/?id=32724) — retail investors to purchasing only the most liquid cryptocurrencies, capped at ₽300,000 (~$3,700) per year per intermediary
- T1[Bank of Russia](https://cbr.ru/eng/press/event/?id=28215) — cryptoassets as a high-risk instrument with no identifiable issuer or jurisdictional guarantee, high volatility and sanctions exposure
- T4 · CoinDesk[2026 Russian cryptocurrency circulation law](https://www.coindesk.com/policy/2026/07/21/russia-s-parliament-passes-crypto-market-law-rules-to-take-effect-sept-1) — judicial protection for holders of digital currencies regardless of prior declaration status
- T4 · CoinDesk[2026 Russian cryptocurrency circulation law](https://www.coindesk.com/policy/2026/07/21/russia-s-parliament-passes-crypto-market-law-rules-to-take-effect-sept-1) — banks and other entities from advertising or promoting cryptocurrency for payments
- T1[Банк России](https://www.cbr.ru/press/event/?id=32719) — The Bank of Russia has stated that non-qualified investors may buy the most liquid cryptocurrencies after passing a test and within a limit of no more than 300,000 roubles a year through any one intermediary, while qualified investors face no cap.
- T1[Банк России](https://www.cbr.ru/press/event/?id=28229) — For digital financial assets, the Bank of Russia has since 1 January 2026 allowed non-qualified investors to buy high-credit-quality DFA with non-variable payouts without limit, DFA linked to inflation, the key rate, precious metals or shares within 600,000 roubles a year, and reserved high-risk DFA to qualified investors.
- T3[Federal Law No. 282-FZ](https://cryptonews.net/news/legal/33597265/) — P2P transfers of digital currency between individuals via digital-depository-administered addresses

### Russia: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾

Tax Code amendments (effective 2025) tax mining/transaction income at 13% up to ₽2.4 million and 15% above (CLM-RU-025, confidence downgraded to Probable per Challenger fold f-001), exempt crypto transactions from VAT while capping income tax at 15% (CLM-RU-026), and monthly reporting is required by the 20th of the following month (CLM-RU-028). A 2026-law reporting obligation covers offshore-recorded holdings (CLM-RU-029). A 2022-era issuer-taxation law (13%/15% by residency) awaits confirmation of final signature/effective date (CLM-RU-027).

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 11 traced claims · Re-verified 2026-10-25

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### Russia: C7 Cross-Border TransferRedEnacted in forceModule confidence: Probable▾

The 2026 law permits unlimited cross-border crypto settlement for foreign trade (CLM-RU-030), building on the 2024 experimental legal regime linked to sanctions-circumvention goals (CLM-RU-031), while restricting residents' outbound personal transactions to foreign bank accounts/regulated intermediaries (CLM-RU-032). OFAC sanctioned the Old Vector/A7/A7A5-Garantex network (CLM-RU-033), and the EU's 20th sanctions package bans EU persons from Russian/Belarusian crypto and DeFi platforms including the digital ruble and RUBx (CLM-RU-034). The A7A5 ecosystem has processed an estimated $119.7bn to date (CLM-RU-035).

Periodic update · new data 2026-10-25

#### Cross-Border Transfer

Russia has confirmed, as of mid-October 2026, that authorised exporters and importers may use crypto assets and digital financial assets to settle cross-border trade without transaction-value limits. This permission is available whether settlement runs through an intermediary or directly from any wallet type, and it operates alongside the newly opened 282-FZ licensing gateway rather than depending on it. The liberalisation sits apart from the retail-facing restrictions that continue to apply to individual purchasers: the retail and qualified-investor purchase caps reported elsewhere remain in force even as authorised trade-settlement use has been freed of transaction limits. The detailed procedural rules governing how an authorised exporter or importer establishes eligibility, and how a settlement transaction is documented for regulatory purposes, are only partly sourced in the material available this period; no primary Bank of Russia procedural text has been retrieved to confirm the mechanics in full.

#### Outlook

The unresolved procedural detail behind the exporter/importer authorisation is the principal gap to watch, since it determines in practice how widely the unrestricted cross-border settlement permission can actually be used. Given the explicit trade-settlement framing of this liberalisation, any further easing or tightening is likely to track the broader sanctions and correspondent-banking environment rather than domestic consumer-crypto policy.

Periodic update · new data 2026-10-18

#### Cross-Border Transfer

Domestic Russian law under 282-FZ permits the use of crypto assets as settlement under foreign-trade contracts, without a stated amount limit on such use, giving Russian entities a lawful channel for crypto-settled cross-border commerce. This domestic permission operates in a landscape shaped by an external, EU-imposed prohibition that runs in the opposite direction: Council Regulation (EU) 833/2014, as amended by the EU's 19th sanctions package which took effect on 25 January 2026, prohibits EU-based operators from providing crypto-asset services, specified payment services, or e-money issuance to Russian nationals, Russian residents, or entities established in Russia. The two regimes are independent of one another in legal basis and in the authority imposing them: Russia's own domestic law creates a lawful crypto cross-border channel for its own entities, while EU law simultaneously forecloses that same channel to any EU-regulated counterparty seeking to service Russian persons or entities. The result is a cross-border transfer environment that is permissive as a matter of Russian domestic law but constrained as a matter of EU-side regulatory prohibition, meaning the practical availability of any given cross-border crypto channel depends on which jurisdiction's counterparty and rules govern the specific transaction.

#### Outlook

The durability of the EU prohibition is tied to the EU's own sanctions-renewal cycle rather than to any Russian domestic development, so the external constraint on cross-border crypto settlement is likely to persist independently of further changes to 282-FZ. Any expansion of EU sanctions scope, or any move by Russia to formalise crypto settlement channels through additional jurisdictions not covered by the EU prohibition, would be the next material development to watch in this space.

Periodic update · new data 2026-10-11

#### Cross-Border Transfer

Article 1(7)(1) of Federal Law No. 282-FZ creates an explicit domestic legal basis for using digital currency or digital rights as payment or consideration under a foreign-trade contract between a Russian resident and a non-resident, effective 1 September 2026. This is a notable liberalisation of RU's cross-border posture on crypto use, moving from tolerated practice toward an express statutory permission.

The provision carries an equally explicit limitation that governs its practical reach: use of digital currency under Article 1(7)(1) does not immunise a transaction from sanctions, export-control, or AML obligations imposed by the EU, UK, US, or other jurisdictions. This creates a structural conflict-of-laws position: a transaction lawful under RU domestic law may still expose a non-resident counterparty, or a resident counterparty dealing with sanctioned-adjacent infrastructure, to foreign legal risk. That gap is persistent rather than transitional, since it follows from the jurisdictional reach of foreign sanctions regimes rather than from any feature of RU law that might be revised.

#### Outlook

The practical operation of Article 1(7)(1) in live foreign-trade settlement, including the extent to which counterparties in non-sanctioning jurisdictions actually rely on it, is the development to watch; the conflict-of-laws exposure it creates for any counterparty subject to EU, UK or US jurisdiction is a structural feature unlikely to be resolved by RU domestic legislation alone.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 9 traced claims · Re-verified 2026-10-25

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### Russia: C8 AML/CFT RegimeAmberEnacted in forceModule confidence: Probable▾

aml_cft_regime is a subscribed surface pending consolidation into financial-integrity per fleet module-subscription doctrine; no independent claims were scored for RU this cycle. The amber traffic light reflects elevated sanctions/AML risk context surfaced incidentally through cross_border_transfer evidence (OFAC and EU designations against Russian crypto infrastructure), rather than an independent assessment of this module.

Horizon · 2027-Q1 (± six months) Rosfinmonitoring RUB 60,000 crypto-transaction reporting threshold Consultation · Tier 4 source

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25

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