Russia's regulated crypto framework is being built around cross-border settlements, and this is its key economic function. However, sanctions pressure, particularly the 20th EU sanctions package, is gradually narrowing opportunities to access international markets, calling into question the very viability of this structure. Nevertheless, the deep decentralization of digital assets and the irrepressible demand for alternative payment channels make complete isolation of the framework a technically unfeasible task.
Key Beneficiaries and Creation Goals
The framework is being created not for a single group, but for the entire spectrum of market participants. For foreign trade companies, this is a natural expansion of EPR mechanisms with the provision of additional powers. Investment divisions gain access to new digital products, including digital financial assets (DFAs), and the ability to attract international capital in public networks. Financial and credit institutions see the framework as a tool for expanding lending — from long-term to short-term — as well as for implementing digital instruments like factoring and securitization. For the state, represented by the Central Bank, the Ministry of Finance, and the Federal Tax Service, it means bringing the de facto existing industry out of the shadows into a taxable and controlled field, addressing AML/CFT issues and FATF compliance requirements.
Sanctions: Threat or Stimulus?
Contrary to expectations, sanctions are not a fatal threat to the framework. Market participants are aware of the risks of secondary sanctions and are already applying protective measures. These include: interacting with CIS-licensed solutions and intermediary links to obscure the trail; managing the issuance of stablecoins based on banks, making it impossible to block the entire system at once; and creating backup options through DFAs, investment products, and tokenization. In essence, sanctions only accelerate the transition from gray schemes to institutional solutions.
Who Wins and Who Loses?
In the long term, everyone wins except the black market. Its financial flows through unregulated organizations will gradually shrink. However, in the short term, the situation is harsher: large banks already deploying their own infrastructure come out ahead. Small and medium-sized capital, as well as startups, lose out. They have three paths: migration to other jurisdictions, selling their business to banks, or creating niche products that banks currently lack time for but which are in demand by specific clients.
Crypto Depositories and Wallets: Who Are They For?
Crypto depositories and regulated wallets are being created for clients who require a legal framework. Buying real estate or a car with cryptocurrency, transferring funds abroad — all of this requires proof of the legal origin of funds and readiness to address tax issues. This is precisely the function that depositories perform. Excesses on the part of market participants and the state are inevitable, but they are more likely due to incompetence than malicious intent. New products are complex at both the technical and user levels, and it will take years to improve the qualifications of all participants.
Analyst's Opinion: The regulated crypto framework in Russia is not an attempt to circumvent sanctions, but an inevitable stage in the evolution of the financial system. It will only give the "green light" to institutional players with large client bases, leading to market consolidation and the departure of small independent alternatives. This is a painful but necessary process for long-term sustainability.