Russia's crypto framework is being built for cross-border settlements, but sanctions are gradually closing the exit abroad — this paradox calls into question the economic rationale of the entire structure.
A long-standing debate has been brewing in the professional community: for whom and why is a regulated cryptocurrency framework being created in Russia? Some see it as a natural expansion of the experimental legal regime (ELR) to a wide range of participants. Others view it as the state's attempt to bring the de facto existing industry out of the shadows, making it taxable and compliant with FATF requirements.
In my view, the key question is not "why," but "whether" this system can operate effectively under unprecedented sanctions pressure. Let's break it down.
Who is the crypto framework being created for?
Analysis shows that the benefits of implementing the framework are distributed unevenly:
- For foreign trade settlements: this expands the ELR and grants additional powers to foreign economic activity participants.
- For investment divisions: expands the range of digital products, including digital financial assets (DFAs), and attracts international investors.
- For financial organizations: the ability to expand lending and introduce new instruments such as factoring and debt securitization.
- For the state: bringing the industry into a regulated field, solving AML/CFT issues.
However, there is another point of view: for large banks and the regulator, the framework is already operational. The share of cross-border transfers attributed to crypto is growing by 20-30% annually. The only problem is access to crypto market instruments for major players — and this can only be ensured through legislation.
Sanctions: threat or incentive?
Many fear that the infrastructure elements of the framework will fall under secondary sanctions. However, I consider these concerns exaggerated. The system will operate just like fiat transactions — through licensed solutions from CIS countries, managing stablecoin issuance based on banks, and using alternative solutions like DFAs.
It is important to understand: it is technically impossible to block the entire issuance system at once — it can be easily duplicated, launched from scratch, and scaled within Russia. This is not a vulnerability, but a feature of decentralized technologies.
Who wins and who loses?
My analysis shows that in the long term, only the black market will lose — it won't disappear, but its financial flow through unregulated organizations will gradually decline. All other participants will win.
However, there is also a harsher assessment: large banks are already deploying their own infrastructure and know how to work with crypto instruments. Small and medium capital, as well as startups, are losing. For them, there are three paths: migration, selling to banks, or creating niche products that banks don't yet have time for.
Crypto depositories: who are they for?
Crypto depositories and wallets are not created for anonymous users, but for clients who need to legally conduct large transactions — buying real estate, transferring funds abroad. This is a legal requirement. The function of depositories is to help users stay within the legal framework.
My conclusion: the regulated crypto framework in Russia is not an attempt to circumvent sanctions, but an inevitable stage of market institutionalization. Sanctions will only accelerate this process, forcing participants to seek more sustainable and transparent mechanisms. However, the success of the entire structure will depend on how quickly the regulator and businesses can adapt to new realities and how flexible the system itself proves to be. For now, I see more questions than answers.