The Bank of Russia has issued the third part of its clarifications on the application of the cryptocurrency law, and this package of answers noticeably reshapes the regulatory contour. The regulator detailed how the new regime works in contentious situations: what to do with tokens that have an issuer, whether exchanges can operate in DeFi, from which day depositories are obliged to comply with all requirements, and how to qualify the purchase of securities for digital currency.
All recommendations are based on Federal Law No. 282-FZ, which sets the rules for the Russian digital currency market. This is already the third batch of clarifications — the regulator is consistently closing the practical gaps of the new regime.
Tokens with an issuer will not fall under the definition of digital currency
The law describes digital currency as an asset without a specific issuer. Market participants raised the question of whether this definition would extend to coins and tokens backed by the company that issued them. The Bank of Russia's answer is negative: there are no plans to expand the definition. If a digital asset has an issuer, it may be classified under a different category — a foreign digital instrument, a separate concept of the law enshrined in paragraph 20 of part 1 of article 2.
For investors, this means that stablecoins and other tokens with an issuer will live by their own rules, not by the rules for bitcoin and similar assets without an issuer.
Exchanges allowed to operate in DeFi
The second block concerned Russian crypto exchanges: whether they can execute transactions in DeFi protocols — decentralized services on smart contracts without an intermediary — and store digital currencies at blockchain addresses not managed by any digital depository. The regulator answered in the affirmative. Such operations are not considered circulation of digital currencies within the meaning of paragraph 3 of part 1 of article 2 of No. 282-FZ, therefore the restrictions related to circulation do not apply to them.
In essence, this opens up access for exchanges to decentralized liquidity and to self-custody of assets outside the depository infrastructure.
Depositories are obliged to comply with all rules from day one
A digital depository is an organization that keeps records of clients' digital currencies and is included in a special register. The market was interested in which requirements of the law it must fulfill immediately after inclusion in the register. The Bank of Russia explained: there is no transition period. From the day of inclusion in the register, a depository is obliged to comply with all requirements of No. 282-FZ on executing transactions and operations, specifically pointing to articles 30, 31, 34 and 35 of the law.
For clients this is a plus: if an organization is already listed in the register, it operates under the full set of rules, not just some of them.
Purchase of securities for cryptocurrency recognized as barter
The last clarification concerns transactions in which securities are paid for with digital currency. The key question is whether to qualify such a transaction as a purchase and sale or as a barter, that is, an exchange of one asset for another. The answer depends on whether money is involved in the transaction. If rubles are not transferred under the terms, it is a barter. At the same time, the regulator emphasized that limits cannot be circumvented through such a structure: the restrictions established by law for an investor when purchasing digital currency under a purchase and sale agreement also apply when acquiring it under a barter agreement.
For investors this is an important point: the scheme of "gave shares, received cryptocurrency" is formally not a purchase, but it still falls under the same restrictions.
What the regulator explained earlier
The new answers supplement the two previous packages. In the first part of the FAQ, the Bank of Russia addressed basic questions: digital currencies are not classified as CFA, and foreign stablecoins circulate under the rules for cryptocurrencies regardless of how market participants classify them. USDT will be able to enter organized trading after Directive No. 7441-U comes into force.
The regulator also reminded about the restrictions from July 1, 2027. From that date, P2P transactions between individuals will be prohibited, operations with digital currencies will become possible only through licensed brokers and exchanges from the Central Bank register, and the withdrawal of coins to one's own non-custodial wallet and transfers between individuals through a depository are not permitted by law.
In the second part, the regulator moved on to practice. Qualified investor status obtained earlier for all types of transactions also applies to digital currencies. Transferring one's own coins to a depository does not require testing, and companies with multiple roles in the market undergo it once. A crypto exchange is obliged to settle with the client immediately on the delivery-versus-payment principle and must have at least four key positions. The depository itself determines how to verify a foreign wallet and can operate without a separate Central Bank act on digital analysis. Banks have the right to value digital currency based on quotes from foreign exchanges if they have access to transactions on them.
Cryptalist analysis: The third part of the FAQ consolidates an important shift: the regulator is effectively legalizing for licensed exchanges the ability to work with DeFi and to self-custody assets, separating the concepts of circulation and technical operations. At the same time, the strict position on tokens with an issuer and the absence of a transition period for depositories signal a course toward strict compliance without concessions. For the market, this means consolidation of liquidity around players from the Central Bank register and the gradual displacement of gray P2P schemes by 2027.