The Law "On Digital Currencies" in the Russian Federation: a three-tier market model and a dual development vector
The Russian crypto industry is entering a new era. The adoption of the law "On Digital Currencies and Digital Rights," combined with the unprecedented 21st EU sanctions package, is shaping a hybrid model for the digital asset market. It combines a regulated banking circuit for legal fiat operations and a decentralized segment for cross-border and protected transactions.
Key analyst Nadezhda Surova, a member of the Council for the Development of the Digital Economy under the Federation Council, has thoroughly examined the essence of the new regulation. The law establishes the legal status of cryptocurrencies, permitting their mining, ownership, alienation, and use in foreign trade settlements with non-residents. At the same time, domestic settlements in cryptocurrency within the Russian Federation remain strictly prohibited.
Three Levels of Infrastructure
According to the analysis, the law creates a three-tier model for organizing the circulation of digital currencies. The first level consists of existing exchange platforms — the Moscow and St. Petersburg exchanges. They have well-established infrastructure, active licenses, and clearing mechanisms. Logically, they will be the first to receive permits for organizing trading.
The second level is formed by financial brokers with a client base and licenses from the Bank of Russia: Sber, T-Investments, BCS, Finam, and VTB. The third level is allocated to exchangers and the OTC segment. Requirements for business reputation and AML/CFT procedures here effectively exclude the legalization of "gray" exchange offices.
The predicted scenario involves banks creating subsidiaries or new legal entities entering the market under the control of well-known financial groups. Sber holds a special position as the only participant present at all three levels simultaneously.
External Pressure and Adaptation
The second vector of development is external sanctions pressure. The 21st EU sanctions package has for the first time affected the digital financial asset sector on such a large scale, including crypto operators in sanctions lists. This creates risks for infrastructure oriented toward European jurisdiction and stimulates a shift in activity toward decentralized (DEX) and friendly platforms.
The market demonstrates resilience developed over the previous 20 packages. Expected directions of transformation include an increase in the share of DEX and P2P operations, a rise in the number of stablecoins, expansion of settlements through friendly jurisdictions, and development of the digital financial assets (DFA) market.
Cryptalist expert opinion: The adoption of the law is not just legalization but the creation of a clear market architecture. However, the key challenge is the balance between strict banking control and the need to preserve decentralized channels for foreign economic activity. The success of the model will depend on how flexibly the regulator can adapt to the realities of sanctions pressure and technological innovation.