A new crypto infrastructure in Russia will not earn trust if its only foundation is the obligation to go through an intermediary. The market has already moved from debating the model to assembling it, and now the main thing is for the system to protect the client rather than simply adding a paid layer.
The discussion was prompted by the Bank of Russia's first practical steps: the regulator added the first digital depositories and crypto exchanges to its registries. From July 1, 2027, residents that are not digital currency circulation organizations will be able to conduct transactions only through or with such infrastructure participants.
What the intermediary registry lacks
A digital depository is an organization that, after being included in the Central Bank's registry, gains the right to keep records of cryptocurrency and digital rights, formalize their transfer, and provide access to identifier addresses. However, registry status alone does not answer the key security questions.
It is proposed to assess the maturity of the system by how the existence of client assets is confirmed, how they are separated from the intermediary's own property, how refunds are structured in the event of a failure or bankruptcy, and who compensates for damages.
The topic of self-custody was raised separately. The Bank of Russia's clarifications state that an individual is not entitled to transfer cryptocurrency from a digital account to their own non-custodial wallet — that is, a wallet whose keys are held only by the owner. This is a specific restriction that cannot be extended to all cases of storage and all categories of participants. Transparency of operations should be discussed separately from the question of who controls access to the asset, and ways should be sought to confirm wallet ownership without concentrating risks among a narrow circle of companies.
For intermediation to make economic sense, requirements for infrastructure participants need to be established in advance: disclosure of fees, timelines for executing operations, grounds for suspending services, and the procedure for appealing decisions. The client must understand not only the price of entering the system but also the conditions for exiting it.
What this means for business and investors
For companies, the key issue is foreign trade. Settlements in cryptocurrency with foreign counterparties and payment for goods within Russia are different legal situations. Three actions must not be conflated: selling mined cryptocurrency, buying it for settlements, and performing a foreign trade contract with its help. A special procedure for one of them does not exempt from the requirements for another.
Miners need a clear economics of the entire chain — from the cost of energy and equipment to where and on what terms the mined asset is sold and how revenue returns to circulation. Guaranteeing mining profitability is not proposed — only providing rules by which risks can be calculated. For investors, it is important not to expect the impossible: confirmed origin of an asset does not guarantee that it will be accepted abroad, since the Bank of Russia classifies sanctions risks as risks of crypto assets.
Ultimately, five areas for discussion were identified: protection of client assets, transparent fees, predictability of service, separate routes for miners, exporters, importers, and investors, as well as industry participation in developing standards. Self-regulation, meanwhile, should not replace state supervision.
Cryptalist analysis: The proposed model establishes an intermediary architecture as a mandatory layer of access to cryptocurrency, which reduces operational risks for the mass client but at the same time narrows the space for self-custody. The key factor for trust will be not the fact of inclusion in the registry but the transparency of mechanisms for segregating assets and returning funds in the event of bankruptcy. For the market, this is a signal: competition is shifting from speed of entry to quality of exit and protection of capital.