Russia's regulated crypto ecosystem is being built with a focus on cross-border settlements and attracting institutional money. However, the paradox is that sanctions pressure, especially under the EU's 20th package, is gradually narrowing opportunities for entering international markets. This calls into question the economic viability of the entire structure if it remains confined solely within Russia.
Who the infrastructure is being created for
The crypto ecosystem in Russia is not just an experiment but a multi-layered system aimed at different categories of participants. For foreign trade companies, this is a natural expansion of the experimental legal regime (ELR) to a wide range of participants. Investment divisions will gain access to new digital products, including digital financial assets (DFAs), and the ability to create secondary turnover on public networks. Banks and financial organizations will be able to expand lending and introduce instruments such as factoring and debt securitization. For the state, represented by the Central Bank, the Ministry of Finance, and the Federal Tax Service, this means bringing the de facto existing industry out of the shadows into the taxable sphere and meeting FATF requirements.
But the main problem that regulation solves is providing access to crypto instruments for large banks and the regulator. As experts rightly note, major players are capturing the market, and this is only possible with legislation in place — any legislation, as long as legal mechanisms exist.
Sanctions and ecosystem resilience
Circumventing sanctions is not the primary goal of creating the crypto ecosystem. Market participants are aware of the risks and are already taking measures to mitigate them. Fears that infrastructure elements will fall under secondary sanctions are exaggerated. The system will operate similarly to fiat transactions. Key protective measures include: interacting with licensed solutions from CIS countries to obscure the trail, managing the issuance of stablecoins based on banks (which technically makes it impossible to block the entire system), and using alternatives like DFAs and tokenization as a backup option.
Is there a point in a closed ecosystem
The value of cryptocurrency lies in its cross-border nature. If the ecosystem becomes completely isolated within Russia, its economic meaning will sharply decline. However, complete isolation is technically impossible due to decentralization. It is possible to restrict entry and exit into fiat outside of Russia, but not all countries support the policy of isolating Russia, and the DeFi sector is so developed that it is impossible to put up all barriers without killing the instruments.
Who wins and who loses
In the long term, everyone except the black market will benefit. Its financial flow through unregulated organizations will gradually decrease. However, there is also a harsher assessment: large Russian banks are already deploying their own infrastructure and know how to work with crypto instruments, so they are the winners. Small and medium-sized capital, as well as startups, lose out. They have three paths: migration to other countries, selling to banks, or creating niche products that banks currently lack the time for.
Who crypto depositories are being built for
Crypto depositories and wallets are being created for clients — this is a legal requirement. Buying a car or real estate with crypto, transferring funds abroad require proof of the legal origin of the funds. The function of depositories and regulated wallets is to help users within the legal framework. Excesses are inevitable, but they are often associated not with malicious intent but with incompetence: new products are technically and user-wise complex, and it will take years to improve the qualifications of all participants.
My analysis: The Russian crypto ecosystem is not an attempt to create a "crypto offshore" but an inevitable stage in the evolution of the financial system. Regulation will only give the "green light" to institutional players with large client bases. Independent alternatives will likely either migrate or be absorbed. The key question is whether the ecosystem can maintain its cross-border function without turning into another "walled garden."