The 21st EU sanctions package against Russia: the crypto market expects bifurcation and rising costs
The European Union has targeted the cryptocurrency sector on such a large scale for the first time as part of the 21st sanctions package. Russian experts we interviewed agree on one point: the blow will be severe, but its consequences largely depend on whom exactly Brussels classifies as "crypto operators." The market has already weathered 20 packages of restrictions, and this time the very infrastructure of digital finance has come under attack.
Nadezhda Surova, a member of the Council for the Development of the Digital Economy under the Federation Council, considers the adoption of these measures a precedent-setting step. In her assessment, restrictions may affect platforms for exchanging fiat currencies for crypto assets, transaction services involving sanctioned banks, and individuals involved in crypto infrastructure to circumvent banking restrictions. The formal consequences include account blocking in European jurisdictions, a ban on transactions through European payment systems, and restricted access to liquidity from European counterparties.
The expert emphasizes that oil sanctions create an additional backdrop of ruble volatility, which traditionally increases demand for digital assets as a capital preservation tool. In her view, the Russian crypto market demonstrates resilience developed during adaptation to the previous 20 packages. Expected areas of transformation include a shift in activity to decentralized platforms and the P2P segment, growing demand for stablecoins as a means of settlement, and an increase in transaction volumes through friendly jurisdictions.
According to Surova, the decisive factor will be the specific content of the term "crypto operators" in the official bulletin of the EU Council. If the definition covers all platforms serving Russian users, the consequences will be significant. If it applies only to structures linked to sanctioned banks and the defense sector, adaptation will proceed with minimal losses.
Alexey Zyuzin, General Director of the Institute for the Development of the Crypto Industry, predicts that the new package will significantly limit the international component of the market, which is taking shape after the adoption of the new bill. Russian regulated participants will become more transparent and, consequently, more visible to foreign exchanges, stablecoin issuers, custodians, and analytical services. This increases the likelihood of service denials, blocking of associated addresses, and additional checks on the origin of funds.
Zyuzin is confident that two circuits will form. The first is a legal domestic market under the control of the Russian regulator, focused primarily on qualified investors and Russian infrastructure. The second is a cross-border segment where elevated sanctions and technological risks will persist. The most vulnerable will be projects relying on international settlements, while the least vulnerable will be domestic digital financial assets (DFAs) denominated in rubles and circulating within the Russian regulated framework.
Nikolay Zagvozdkin, Director of Product Development for "Crypto" at RBC, notes that it is still difficult to objectively assess the significance of the 21st package — there is no full list of crypto platforms affected by the restrictions. However, the very fact of measures against crypto companies, in his words, indicates that Europe is effectively acknowledging that cryptocurrency has ceased to be a parallel market for enthusiasts and has turned into a major sphere aiding Russia's foreign economic activity.
According to Zagvozdkin's assessment, this primarily concerns companies such as A7 and the associated stablecoin A7A5. To fully grasp the consequences, one must wait for the list of companies, but it is already clear that the restrictions will impact businesses that vitally need regular cross-border payments. Small and medium-sized businesses will likely suffer more, while large companies will, one way or another, find ways to operate in the current situation. All regulated platforms will become even stricter in checking the origin of funds, client geography, and the connection of wallets to Russian counterparties. At least at some stage, working with crypto will become more expensive, slower, and slightly less transparent.
Analytical conclusion from Cryptalist: The 21st package is not just another round of sanctions, but an attempt by the EU to cut off oxygen to key channels of crypto-fiat exchange and cross-border settlements for Russian businesses. The market will inevitably fragment: the domestic regulated segment (DFAs, tokens under the control of the Central Bank) will receive an impetus for development, while the "gray" zone of P2P and decentralized exchanges will become riskier and more expensive. The key factor of uncertainty is the specific list of crypto operators, which the EU has yet to publish. It is this list that will determine how deep the rift will be and which players will end up on the periphery of the new financial architecture.