The "On Digital Currencies" Law establishes a three-tier model of the crypto market in Russia: expert analysis
The adoption of the law "On Digital Currencies" combined with the 21st EU sanctions package creates a unique, "hybrid" architecture for the Russian digital asset market. This is not just a regulatory initiative, but the formation of two multidirectional yet complementary development vectors that are radically changing the industry landscape.
What does the new law establish?
The legislative act finally introduces cryptocurrencies into Russia's legal framework. It clearly permits the ownership, purchase, sale, and mining of digital currencies, as well as their use in foreign trade settlements with non-residents. A key point is that domestic settlements in cryptocurrency within the territory of the Russian Federation remain prohibited. This regulatory act lays the foundation for a three-tier circulation model, where each level has its own infrastructure and licensing requirements.
Three tiers of the new infrastructure
First tier: Existing exchange platforms, such as the Moscow and St. Petersburg exchanges. They possess ready-made infrastructure, licenses, and well-established clearing mechanisms. Logically, they will be the first to receive permission to organize trading in digital currencies.
Second tier: Financial brokers with a client base and licenses from the Central Bank of the Russian Federation — Sber, T-Investments, BCS, Finam, and VTB. Their key advantage is their existing data storage system and client trust. They can become a bridge between traditional finance and the new crypto segment.
Third tier: Exchanges and the OTC segment. The requirements for business reputation and KYC/AML procedures for this level are so high that they practically exclude the legalization of "gray" exchange offices. This means the market will consolidate around large, trusted players.
Sber's position and the external vector
Sber occupies a unique position, being present at all three levels simultaneously. German Gref's statement at the St. Petersburg International Economic Forum (SPIEF) about the intention to perform the full range of operations, including exchanging fiat money for cryptocurrency, confirms the bank's ambition to become a key hub. Its infrastructure and legislative framework were developed in parallel, giving it an undeniable advantage.
On the other hand, the 21st EU sanctions package has, for the first time, affected the digital asset sector on such a large scale, including crypto operators in the sanctions lists. This creates risks for infrastructure oriented towards the European jurisdiction and stimulates a flow of activity towards decentralized (DEX) and friendly platforms (P2P).
As a result, we are witnessing the formation of a hybrid model: a regulated banking circuit for legal operations (withdrawal into rubles, lending secured by crypto) and a decentralized segment for cross-border and protective transactions. For retail holders, this means the emergence of a civilized circuit for fiat exit and lending, but without significant changes in the use of hardware wallets or international exchanges.
My expert opinion: This three-tier model is a pragmatic response to a dual challenge: the need to legalize the market and simultaneously protect against external pressure. The key beneficiary will be Sber, which is already ready to act as a "state crypto bank." However, the long-term success of the model will depend on how effectively the regulator can balance control and innovation, without stifling the decentralized segment, which is becoming increasingly important for cross-border transactions.