Russia is actively building a regulated crypto framework, primarily focused on cross-border settlements. However, the paradox of the situation is that mounting sanctions pressure is gradually narrowing the opportunities to operate outside the national financial system. This calls into question the very economic viability of the entire structure. Let's examine who this framework is being built for and whether it has a future.
Who is the crypto infrastructure being built for?
The crypto framework in Russia is not a single product but a multi-layered ecosystem, the benefits of which are distributed among different categories of participants. For foreign trade companies, it is a natural extension of the Experimental Legal Regime (ELR) to a wider range of participants, granting them additional powers for conducting international payments. Investment divisions gain access to new digital products, including opportunities for Digital Financial Assets (DFAs), attracting international capital, and creating secondary turnover in public networks. Financial and credit institutions expand their lending portfolio—from long-term to short-term—and introduce digital instruments such as factoring and debt securitization. For the state, represented by the Central Bank, the Ministry of Finance, and the Federal Tax Service, the key task is to channel the de facto existing shadow industry into a regulated, taxable stream, addressing AML/CFT issues and FATF compliance requirements.
It is important to understand: for each of these groups, there will be services that are currently in acute shortage. Regulation in this case is not so much a prohibition as it is the creation of a "green corridor" for major players who cannot enter the market without clear legislation.
Sanctions: Threat or Catalyst?
There is a widespread belief that the crypto framework is being created solely to circumvent sanctions. However, this is just one of the tasks, and not the most important one. Pressure will certainly continue—and is already being applied within the framework of the 20th EU sanctions package. But market participants are aware of this and are taking measures in advance to mitigate risks. Fears that infrastructure elements will fall under secondary sanctions are exaggerated. The system, similar to fiat operations, will operate smoothly if the chain is properly structured.
Key mechanisms for protection against sanctions risk include: using licensed solutions in CIS countries and other intermediate links to obscure the trail; managing the issuance of stablecoins based on banks, which technically makes it impossible to block the entire issuance system—it is easily duplicated and scalable; and applying alternative solutions (DFAs, investment products, tokenization) as a backup option for the most severe 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, its economic rationale would sharply decline. However, such a situation is practically impossible precisely because of the decentralized nature of digital currencies. One could attempt to restrict fiat entry and exit points 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 instruments.
The economic rationale of the Russian crypto framework is to give the market the opportunity to bypass fiat restrictions using cryptocurrency and profit from it. This is not about isolation, but about creating an alternative channel for international settlements that is resilient to external pressure.
Who Wins and Who Loses?
In the long term, all legal market participants will benefit. The black market will not disappear entirely, but the financial flow through unregulated organizations will gradually decrease. However, the balance of power is shifting: major Russian banks are already deploying their own infrastructure and know how to work with crypto instruments, putting them in a winning position. Small and medium-sized capital, as well as startups, lose out—they have three paths: migration, selling to banks, or creating products that banks currently lack time for but that are in demand by the market.
Regulation changes the market and gives the "green light" only to institutional players with large client bases. The new segment of users of crypto depositories and crypto wallets consists of existing traditional players, bank clients who will receive the same service at their preferred bank.
Expert Opinion: The Russian crypto framework is not an attempt to "hide" from sanctions, but a pragmatic step towards legalizing and institutionalizing an already existing market. Sanctions only accelerate this process, forcing the search for more sustainable and transparent mechanisms. In the next 2-3 years, we will see market consolidation around major banks and the gradual displacement of illegal services. However, the key challenge will remain the same: can this system be truly cross-border without turning into another "walled garden"?