Crypto news

Major Russian banks have intensified compliance procedures regarding corporate clients dealing with USDT and other crypto assets. This applies not only to companies participating in the experimental legal regime (ELR), but also to those formally outside this sandbox. According to my data, credit institutions are requiring legal entities to provide a detailed justification of the economic rationale for acquiring stablecoins, as well as to confirm that the counterparty is included in a certain registry of digital currency exchange operators maintained by the Bank of Russia. The problem is that such a registry does not currently exist in reality.

De-risking as a strategy, not an instruction

In this situation, it is important to understand the banks' motivation. They are not acting on a direct directive from the Central Bank, but rather in the logic of self-insurance and preventive de-risking. Since the announcement of the digital currency law and the launch of the ELR "sandbox," the regulator has signaled that cryptocurrency is becoming a full-fledged financial instrument. This, in turn, prompts banks' compliance departments to pay heightened attention to the nature of the origin of funds and the cryptocurrency itself. The requests currently being sent to clients are an attempt by banks to minimize risks in advance, rather than to follow a clear directive from above.

A number of industry Telegram channels suggest that banks are relying on a certain letter from the Central Bank. However, based on my analysis of the situation, the initiative comes more from Rosfinmonitoring, which is responsible for law enforcement, rather than from the Central Bank, which issues regulatory acts. There are no legal risks for banks here: all their requirements fall within the framework of Federal Law No. 115-FZ. They have every right to request information about the origin of cryptocurrency, even to the point of absurd formulations—this is their legal right in the fight against money laundering.

The registry will appear in autumn but will be closed

According to my forecasts, the registry of digital currency exchange operators will be created by autumn of this year. Its key characteristic will be maximum confidentiality. This is obvious: ELR participants use cryptocurrency primarily to circumvent sanctions restrictions, so a public registry would contradict the very essence of the mechanism. The Central Bank will establish detailed requirements for limits and operating rules for exchangers through separate by-laws. It is precisely this lack of specificity that generates the current uncertainty: the regulatory framework has already been adopted, but its content has not yet been filled with concrete details.

What will be required from companies

Corporate clients, especially ELR participants, will have to disclose the full chain of cryptocurrency origin: where it is purchased, what the source of fiat funds is, as well as ensure transparency in relations with their own clients. Obviously, the burden on the compliance departments of such companies will increase significantly.

At the same time, there is a concession for smaller players: with a turnover below 3.5 million rubles per month, inclusion in the registry is not required. However, even they are forced to buy cryptocurrency somewhere, which automatically raises questions about the source of funds.

The law as a resolution to the collision

Separately, it is worth noting the situation with companies that use USDT not voluntarily, but due to closed SWIFT channels. Currently, they have to explain the economic rationale of the transaction to the bank, and an honest answer effectively documents the sanctions context. The adopted law "On Digital Currency and Digital Rights," which comes into force on September 1, resolves this collision. From that date, settlements in cryptocurrency for foreign economic activity become a full-fledged legal instrument, rather than an exception from the "sandbox." Banks, provided a complete package of documents is available, will be obliged to service such transactions.

My commentary: This situation demonstrates the classic growing pains of regulation: the law has been adopted, but by-laws are lagging behind. Banks, trying to insure themselves, are creating chaos on the ground. However, by September the market will adapt, and we will see consolidation: small illegal exchangers will go underground or close down, while large players will receive clear rules of the game. The transition period until July 2027 will give the market enough time for legalization.