Cryptocurrency law in Russia: not legalization, but strict institutionalization of the market
The Russian digital asset market is entering a new era. The law No. 1194918-8, adopted by the State Duma and signed by the president, is not an attempt to open the doors for retail cryptocurrency trading, but rather the creation of a controlled ecosystem for institutional players. Alexander Brazhnikov, Executive Director of RAKIB, rightly notes: we are witnessing not liberalization, but the channeling of turnover into a regulated framework.
The logic of the law: control instead of prohibition
The document, nearly 300 pages long, forms a full-fledged legal infrastructure. Transactions with digital currencies will be conducted exclusively through registered intermediaries—crypto exchangers, brokers, and management companies, including on organized trading venues. Digital depositories will handle the accounting of asset rights. All intermediaries are required to have Russian registration and be included in the Central Bank's registry, while crypto exchangers must have their own funds of at least 15 million rubles.
A key point: brokers and management companies will be able to work with foreign crypto infrastructure, but only if they hold licenses. The transition period will last until July 1, 2027, when all new digital financial institutions must bring their operations into compliance with the requirements. The concurrently adopted companion law No. 1194929-8 adapts about two dozen existing regulatory acts.
Access to assets: filters and limits
Only cryptocurrencies with an average market capitalization exceeding 5 trillion rubles over two years and an average daily trading volume of at least 1 trillion rubles will be admitted to public trading. Currently, only bitcoin, Ethereum, and USDT meet these criteria, which automatically excludes the vast majority of altcoins.
For individuals, mandatory testing is introduced. Unqualified investors receive a limit of 300,000 rubles per year through a single intermediary and access only to liquid assets. Qualified investors can operate with any cryptocurrencies without restrictions, but they are also required to pass the test. Payment for goods and services with cryptocurrency within the country remains prohibited, including advertising such options. An exception is made for foreign economic activity: exporters and importers can use digital currencies for cross-border settlements without restrictions.
Who wins and who loses
Brazhnikov counts large banks and brokers that already possess licensing infrastructure, as well as foreign trade companies, among the beneficiaries. For them, cryptocurrency becomes a tool for circumventing sanctions restrictions and accelerating cross-border payments. The state, in turn, gains a tax base and transparency of flows.
The most stringent regime awaits the retail unqualified investor. The limit of 300,000 rubles (about $3,700) with mandatory testing is essentially a symbolic admission. The wording "through a single intermediary" leaves open the question of summing limits when working with multiple platforms. Small miners and "gray" firms, according to the expert's estimates, will go underground or shut down due to compliance costs. Transfers to uncontrolled wallets will be restricted: an exchanger will be able to refuse a transaction if fraud is suspected, which effectively pushes self-custody out of the legal framework.
Risks of the economic model
The first risk is isolation from global liquidity. The low capital threshold for exchangers and the registry model mean a disconnect from global markets. Spreads on Russian platforms will remain wide until brokers establish licensed bridges to foreign infrastructure. Retail will continue to use P2P and foreign exchanges—the law does not create an economic incentive to move into the legal field, only legal coercion.
The second risk is the unverifiability of the obligation to notify the Federal Tax Service about foreign cryptocurrency held in non-custodial wallets. The regulator will be able to control fiat gateways—bank transfers to exchanges—but not the assets themselves. The third is the inclusion of USDT in the list of admitted assets. A stablecoin of a private foreign company that freezes addresses upon requests creates a dependence of the legal framework on Tether's decisions and a potential channel for pressure on market participants. The fourth is the transition period as a window of uncertainty: until July 2027, the market operates in a "law exists, licenses do not" mode.
My conclusion: what we face is not legalization in the consumer sense, but institutionalization, bringing Russia closer to the Chinese model of control with a pragmatic sanctions exception for foreign trade. This is a strategic step to attract capital through regulated channels, but for the retail investor, it rather closes doors than opens new opportunities.