The Russian crypto framework is being built not to circumvent sanctions, but to channel the de facto existing industry into a regulated and taxable framework. This thesis, at first glance paradoxical, is actually the key to understanding the entire structure. Sanctions pressure certainly has an impact, but it is neither the cause nor the main goal of creating this system.
For whom and why is the crypto framework being created?
The crypto framework is not a single product, but an ecosystem that will benefit different categories of market participants. For foreign trade settlements, it is a natural extension of the experimental legal regime (ELR) to a wide range of participants. For investment divisions, it expands the range of digital products, including opportunities for digital financial assets (DFAs) and attracting international investors. For banks, it offers new opportunities for lending, factoring, and debt securitization.
For the state, represented by the Central Bank, the Ministry of Finance, and the Federal Tax Service, it is primarily about bringing multi-billion-dollar turnover out of the shadows, solving problems related to AML/CFT, and ensuring compliance with FATF requirements. Thus, it is about a total inventory and formalization of the market.
Sanctions: Threat or Stimulus?
Many fear that the infrastructure elements of the crypto framework will fall under secondary sanctions. However, these risks are recognized and are already being mitigated. Key protective measures include interaction with licensed solutions from CIS countries, decentralization of stablecoin issuance based on banks (which technically makes it impossible to block the entire system at once), and the creation of backup options based on DFAs and tokenization.
The system will operate like fiat transactions: it does not close itself off completely, but only creates controlled gateways for entry and exit. The DeFi sector is so developed that it is technically impossible to erect all barriers without destroying the instruments themselves.
Who wins and who loses?
In the long term, only the illegal market will lose—its financial flows will gradually shift into regulated channels. All other participants will only benefit. However, the balance of power is shifting: large banks, which are already deploying their own infrastructure and know how to work with crypto instruments, are in a winning position. Small and medium-sized capital, as well as startups, on the other hand, lose out. They have three options: migrate to other jurisdictions, sell out to banks, or create niche products that banks currently lack the time to develop.
My Professional Opinion
The Russian crypto framework is not an experiment, but an inevitable evolution. The market has long outgrown the stage of anonymous transactions. Regulation will give the "green light" only to institutional players with large client bases, which will inevitably lead to market consolidation. Small and medium-sized participants that cannot adapt will be forced to leave or be absorbed. This is a tough but necessary stage for building a sustainable and transparent digital economy.