The three-tier model of the crypto market in Russia: how EU sanctions and the new law shape a hybrid infrastructure
The Russian digital asset market is entering a new phase of institutional development. The adoption of the law "On Digital Currencies and Digital Rights" coincided with the 21st package of sanctions from the European Union, and this coincidence is not accidental. Instead of chaotic regulation, we are witnessing the formation of a three-tier architecture that combines both internal legalization and a response to external pressure.
An analysis of the document, already available in the electronic database of the State Duma, confirms: the new regulatory act establishes the legal status of cryptocurrencies, permits their mining, ownership, and alienation, as well as their use in foreign trade settlements with non-residents. At the same time, internal settlements in cryptocurrency within the territory of the Russian Federation remain prohibited. This is a key point that forms two parallel circuits.
Three Levels of Infrastructure
The first level is exchange platforms. The Moscow and St. Petersburg exchanges have ready-made infrastructure, active licenses, and well-established clearing mechanisms. In my assessment, they will be the first to receive permits to organize trading in digital currencies.
The second level is financial brokers with a client base and licenses from the Central Bank of the Russian Federation. Key players here are Sber, T-Investments, BCS, Finam, and VTB. They already have data storage infrastructure and access to retail investors.
The third level is exchangers and the OTC segment. Requirements for business reputation and AML/CFT procedures effectively exclude the legalization of "gray" exchange offices. The predicted scenario is the creation of subsidiaries by banks or the entry into the market of new legal entities under the control of well-known financial groups.
Sber's Special Position
Sber occupies a unique position, being present at all three levels simultaneously. German Gref's speech at the St. Petersburg International Economic Forum in June 2026 confirmed the bank's intention to perform a full range of operations, including exchanging fiat currency for cryptocurrency. Sber's legislative framework and infrastructure were developed in parallel, giving it a head start.
External Vector: EU Sanctions
The 21st EU sanctions package has affected the digital financial asset sector on such a large scale for the first time. Including crypto operators in the sanctions list is a precedent-setting step. This creates risks for infrastructure oriented towards the European jurisdiction and stimulates a flow of activity to decentralized and friendly platforms.
The market demonstrates resilience developed over the previous 20 packages. Expected directions of transformation include: a shift to DEX and P2P, growth of stablecoins, an increase in operations through friendly jurisdictions, and the development of the digital financial assets market.
My expert conclusion: The combined effect of two opposing vectors forms a hybrid model, where the institutional banking circuit will become a "safe haven" for legal operations, and the decentralized segment for cross-border and protective transactions. Retail holders receive a civilized circuit for fiat exit and lending, but the key battle will unfold between exchanges and banks for the right to be the main gateway to the new crypto-ruble.