Russian banks are tightening checks on USDT transactions: businesses are being cross-checked against a registry that does not yet exist.
Major Russian banks have begun requesting detailed explanations from corporate clients regarding transactions involving USDT and other digital assets. This applies not only to companies participating in the experimental legal regime (ELR), but also to those formally outside this "sandbox." As it emerged from conversations with representatives of the banking market and the crypto exchange segment, financial institutions are demanding that clients disclose the economic purpose of stablecoin purchases and confirm that the counterparty is listed in the Bank of Russia's register of digital currency exchange operators. The problem is that this register has not yet been created — it has only been announced.
De-risking, not an instruction
Such actions by banks are not a direct directive from the regulator, but rather a logic of self-insurance. Crypto expert Viktor Pershikov explains: before the signing of the law on digital currencies, there was a regulatory "sandbox" — the ELR, where banks and foreign trade participants learned to interact at the intersection of crypto and fiat. Now that cryptocurrency is becoming a fully regulated instrument, banks' compliance departments are showing heightened concern about its nature and the origin of funds.
Contrary to rumors in Telegram channels about some kind of letter from the Central Bank, the initiative, according to the expert, comes more from Rosfinmonitoring — the agency responsible for law enforcement — rather than from the Central Bank, which issues regulatory acts. There are no legal risks for banks here: all their requests fall within the framework of Federal Law No. 115-FZ. As Pershikov figuratively put it, banks have every right to ask about the origin of cryptocurrency, or even about who Satoshi Nakamoto really is.
The register will appear in the fall and will be classified
The formation of the register of digital currency exchange operators is planned for the fall of this year. The key feature of the future document is maximum confidentiality. The logic is clear: ELR participants use cryptocurrency to circumvent sanctions restrictions imposed by unfriendly countries, so publicity here is unnecessary. At the same time, the Central Bank will establish specific requirements for the register, limits, and operating rules for exchangers through separate by-laws. It is precisely this uncertainty that explains the current nervousness of banks: the legislative framework has been adopted, but its substantive content is still ahead.
What will be required from businesses
In addition to the standard AML/FT documentation package and risk assessments, companies that are bank clients will have to disclose the full chain of cryptocurrency origin: where it was purchased and what the source of funds was. They will also need to ensure transparency in relations with their own clients who use digital assets. Obviously, the volume of paperwork for compliance departments of ELR companies will increase significantly.
The gray zone becomes criminal
For companies providing crypto services within foreign trade activities without being included in the register and without a license, the risks are now not limited to administrative prohibitions. In parallel, draft law No. 1193493-8 is being adopted, introducing criminal liability for illegal circulation of cryptocurrencies with confiscation of illegally exchanged assets. An exception is made for those who use crypto within foreign trade contracts. For small players, a threshold is provided: if turnover is below 3.5 million rubles per month, inclusion in the register is not required. But even they are obliged to purchase assets somewhere, which automatically raises questions about the source of funds.
The law as a resolution of the collision
A separate problem concerns companies using USDT not voluntarily, but due to closed SWIFT channels. Now they have to explain the economic purpose of the transaction to the bank, and an honest answer documents the sanctions context. From September 1, when the law "On Digital Currency and Digital Rights" comes into force, foreign trade settlements in cryptocurrency become a fully fledged legal instrument. Banks, provided all documents are in order, will be obliged to service such transactions. The transition period will last until July 1, 2027.
My comment: The situation demonstrates a classic transition from a gray market to a regulated one, where banks are trying to minimize risks even before the formal infrastructure appears. The requirement to check against a non-existent register is, in essence, a stress test for businesses that must prepare in advance for the new realities. Companies working with USDT should already be building transparent chains of fund origin, so that by the fall, when the register appears, they do not end up among "unreliable" clients.