Russia is building a regulated crypto framework focused on cross-border settlements. However, sanctions pressure is gradually narrowing external corridors, calling into question the economic viability of the entire structure. At first glance, this is a paradox, but upon detailed analysis, it becomes clear: this is not a contradiction, but a necessary stage of evolution.

Who is the crypto framework being created for?

The large-scale project covers several key groups. For foreign trade operations, this is a natural expansion of the experimental legal regime (ELR) to a wide range of participants, granting them additional powers. Investment divisions receive an expanded line of digital products, including opportunities for digital financial assets (DFAs), attracting international investors, and creating secondary circulation in public networks. Financial and credit institutions get a chance to expand lending in all forms, from long-term to short-term, as well as to implement factoring and debt securitization instruments.

The state, represented by the Central Bank, the Ministry of Finance, and the Federal Tax Service, solves a key task — bringing the de facto existing industry into a regulated, taxable field and eliminating issues related to AML/CFT and FATF requirements. For legal entities and individuals in each category, services that are currently in short supply will appear.

Sanctions and Resilience

Circumventing sanctions is not the main goal of the framework. Pressure will increase, as already seen within the 20th EU sanctions package, but market participants are aware of the risks and are taking preventive measures. Fears of secondary sanctions against infrastructure elements are exaggerated. The system will work, just like fiat operations.

Three strategies are used to reduce sanctions risk: interaction with licensed solutions from the CIS and other intermediate links to blur the trail; managing the issuance of stablecoins based on banks, which solves the problem of marking smart contracts and wallets, since it is technically impossible to track and block the entire issuance system as a whole; using alternatives — DFAs, investment products, and tokenization — as a backup option in case of the harshest scenarios.

Does a closed loop make sense?

The value of cryptocurrency lies in its cross-border nature. If the loop turns out to be completely closed within Russia, the economic sense will greatly diminish, but such a situation is impossible due to the decentralization of digital currencies. One can try to restrict entry and exit into fiat outside Russia, but this will not completely close the loop: not all countries support the policy of isolating Russia, and DeFi is so developed that it is technically impossible to put up all barriers without killing the corresponding tools. The economic sense of the Russian framework is to give the market the opportunity to bypass fiat restrictions using cryptocurrency and profit from it.

Who wins and who loses?

Only the black market will lose — it will not disappear completely, but the financial flow through unregulated organizations will gradually decline. Everyone else will only benefit in the long term. However, for small and medium-sized capital, as well as startups, the situation is more complicated. Large banks are already deploying their own infrastructure and know how to work with crypto instruments, so they are in a winning position. Small players have three paths: migration to other countries, selling to banks in the near future, or creating products that banks currently lack time for but that are in demand by the market and specific client banks.

Who are crypto depositories being built for?

Crypto depositories and crypto wallets are being created for clients — this is a legal requirement. The use of cryptocurrency has long gone beyond a narrow circle of anonymous users. Buying a car or real estate with crypto, transferring funds abroad require proof of the legal origin of funds and readiness for questions about taxes. The function of depositories and regulated wallets is to assist users within the legal framework. Excesses on the part of market participants and the state are inevitable, but not so much due to malicious intent as due to incompetence: new products are complex at the technical and user levels and will require years of skill improvement for all participants.

Current independent alternatives are a mystical and temporary concept. Regulation will change the market and give the "green light" only to institutional players with large client bases. We are talking about a new segment of users of crypto depositories and crypto wallets — these are existing traditional players, bank clients, individuals and legal entities who will receive the same service at their preferred bank.

Opinion of a Cryptalist analyst: The Russian crypto framework is not an attempt to hide from sanctions, but a strategic step to integrate digital assets into the national financial system. In the long term, those who can adapt to the new rules of the game will win, not those who try to circumvent them. Small and medium-sized businesses that lack the resources for rapid adaptation risk being left on the sidelines of this process.