The bill "On Digital Currency and Digital Rights," which was supposed to come into force on July 1, 2026, has stalled at the second reading stage. The new deadline is September 1, but judging by the sentiments of market participants, this date may also be postponed. Amid this uncertainty, key players—exchangers and private "money changers"—have already begun restructuring their business models, not so much in anticipation of the law, but in response to external sanctions risks.

An analysis of the situation shows that the market has split. Large exchangers, such as The Hermes Exchange, have taken a wait-and-see approach. They are in no hurry to register and obtain licenses, arguing that "there's no rush" since deadlines keep being pushed back. At the same time, they are ready to quickly legalize if the law is passed. Their foreign economic activity (FEA) continues as usual, without any changes.

Private Operators Go Underground: New Rules of the Game

A completely different picture is observed in the segment of private "money changers." Our anonymous interlocutor from Sochi, who deals in cryptocurrency exchange, deliberately refused legalization. His main argument is the reluctance to end up on regulators' "hit lists." Instead, he has implemented strict precautionary measures:

  • Enhanced client screening: preference is given to trusted partners with whom transactions have already been conducted.
  • AML filtering: mandatory address verification through services to exclude "dirty" coins.
  • Avoidance of transaction splitting: to avoid attracting attention.

Notably, he prefers working with TRC-20 (Tron) standard tokens over ERC-20 (Ethereum). This is not a nod to technical anonymity—both networks are transparent. However, TRC-20 is cheaper, faster, and, more importantly, less densely covered by Western AML tools. In the mass of "gray" USDT turnover on Tron, an individual transaction simply gets lost, which is exactly what "money changers" need.

The Main Driver of Change: Sanctions, Not the Law

Key takeaway: changes in the market are occurring not due to anticipation of the Russian law, but because of EU sanctions pressure. Even major exchanges, such as HTX, have come under fire due to ties with Russia. European regulators are making cryptocurrency that touches the Russian circuit "toxic." As a result, "money changers" are forced to build their own defenses, retreating even deeper into the shadows.

Expert opinion from Cryptalist: The current situation is a classic example of how the lack of clear regulation and external pressure push the market into a gray zone. Russian authorities should consider this: if 97% of miners already prefer to "stay off the radar," then the chosen tactic of "dragging things out" could cause far more damage than any premature regulation. The market is adapting on its own, and these adaptations may be irreversible.