Russia's crypto framework is being built with cross-border settlements in mind, but the paradox is that sanctions pressure is gradually narrowing the corridor for access to foreign markets. This calls into question the very economic viability of the entire structure if it ends up locked within the country.

The key question is: for whom is the regulated crypto infrastructure being created? The answer is ambiguous. Under the new model, benefits are distributed unevenly.

Who needs a crypto framework and why

For foreign trade operations, it is a natural expansion of the experimental legal regime (ELR) to a wider range of participants, granting them additional powers to conduct settlements bypassing traditional channels. For investment divisions, it expands the range of digital products, including opportunities for digital financial assets (DFAs), attracting international capital, and creating secondary turnover on public networks. For financial and credit institutions, it offers the ability to scale lending in the broadest sense—from long-term to short-term—as well as the introduction of digital instruments such as factoring and debt securitization. For the state, represented by the Central Bank, the Ministry of Finance, and the Federal Tax Service, it brings the de facto existing industry out of the shadows into a regulated, taxable field and addresses issues related to AML/CFT and FATF compliance.

For both legal entities and individuals in each of these categories, there will be tools and services that are currently sorely lacking. However, the key problem that regulation in Russia solves is access to crypto market instruments for large banks and the regulator itself. Major players are already taking over the market, and they can only do so under the condition of existing legislation—any legislation, as long as legal mechanisms are in place.

Sanctions as a catalyst, not a killer

Circumventing sanctions is not the primary goal of the framework. Pressure on it will exist—and is already being applied under the EU's 20th sanctions package—but market participants are aware of this and are already taking steps to mitigate risks. Many experts also do not share the concern that infrastructure elements will fall under secondary sanctions. The system will operate smoothly, just as fiat transactions do.

To reduce sanctions risk, three key measures are proposed:

  • Engaging with CIS-licensed solutions and other intermediary links in the payment chain—this will help obscure the trail and reduce the burden on direct channels.
  • Managing the issuance of stablecoins based on banks—this solves the problem of marking smart contracts and wallets, as it is technically impossible to track and block the entire issuance system at once: it can be easily and cheaply duplicated, launched from scratch, and scaled in Russia.
  • Using alternative solutions, including DFAs, investment products, and tokenization—this will serve as a backup option for the most challenging scenarios.

A closed loop: does it make sense?

The value of cryptocurrency lies in its cross-border nature. If the loop is entirely closed within Russia, the economic rationale will be greatly diminished. However, such a situation is impossible precisely because of the decentralization of digital currencies. One could try to restrict entry and exit into fiat outside Russia, but even that would not fully close the loop: not all countries support the policy of isolating Russia, and the DeFi sector is so developed that it is technically impossible to erect all barriers without destroying the corresponding tools.

The economic rationale of the Russian framework is precisely to give the market the ability to bypass fiat restrictions using cryptocurrency—and to profit from it. Regulation will change the market and give the "green light" only to institutional players with large client bases. This refers to a new segment of users of crypto depositories and crypto wallets—existing traditional players, bank clients, both individuals and legal entities, who will receive the same service at their preferred bank.

My analysis: The Russian crypto framework is not an attempt to escape sanctions, but a strategic step toward integrating digital assets into the existing financial system. Large banks and institutional players will benefit, gaining regulated access to new tools. Small and medium-sized businesses, as well as startups, will lose out if they cannot adapt or sell their solutions to banks. The market is heading toward consolidation, and those who fail to integrate into the new ecosystem will be forced to migrate or disappear.