Russia is actively building its own regulated crypto framework focused on cross-border settlements. However, the paradox is that sanctions pressure is gradually narrowing the opportunities to operate outside the country, calling into question the economic viability of the entire structure. Let's examine who this infrastructure is being created for and who will ultimately benefit.

The crypto framework is not just an experimental platform. It offers different benefits for different categories of participants. For foreign trade companies, it is a natural expansion of export-import operations to a wide range of participants, granting them additional powers. For investment divisions, it expands the range of digital products, including digital financial assets (DFAs), and attracts international investors. For financial organizations, it provides an opportunity to expand lending, including long-term and short-term, as well as to introduce digital instruments such as factoring. For the state (Central Bank, Ministry of Finance, Federal Tax Service), it brings the de facto existing industry into a regulated, taxable framework and eliminates issues related to AML/CFT and FATF requirements.

Already, the share of cross-border transfers involving cryptocurrency is growing by 20-30% annually. The main problem that regulation in Russia solves is access to crypto market instruments for large banks and the regulator. 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 the Resilience of the Framework: Myth or Reality?

Many fear that infrastructure elements will fall under secondary sanctions. However, the system will operate smoothly, just as it does with fiat transactions. Three key measures are applied to reduce sanctions risk: interaction with licensed solutions from the CIS and other intermediate links in the payment chain (this helps blur the trail), managing the issuance of stablecoins based on banks (solves the problem of marking smart contracts and wallets), and using alternative solutions, including DFAs, investment products, and tokenization, as a backup option for the most complex scenarios.

Does a Closed Loop Make Sense?

The value of cryptocurrency lies in its cross-border nature. If the loop were completely closed within Russia, the economic sense would be greatly diminished, but 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 this would not completely 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 to give the market the ability 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 entirely, but the financial flow through unregulated organizations will gradually decline. Everyone else will benefit in the long term. However, there is a harsher scenario: Russian banks are already deploying their own infrastructure and know how to work with crypto instruments, so they come out ahead. Small and medium capital, as well as startups, lose out, and they currently have three paths: migration to other countries, selling to banks in the near future, or creating products that banks lack time for but that are needed by the market and specific client banks.

Who Are Crypto Depositories Being Built For?

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

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, individuals, and legal entities who will receive the same service at their preferred bank.

Expert opinion: The creation of a crypto framework in Russia is not just a reaction to sanctions, but a strategic step toward legalizing and institutionalizing the crypto market. However, the key challenge is the balance between control and preserving the cross-border nature of digital assets. If the regulator overdoes isolation, the framework risks becoming an expensive "walled garden," devoid of its main advantage — global liquidity and decentralization.