Russian banks have begun requiring companies to comply with a non-existent registry: what is happening with USDT transactions
Russia's largest banks have tightened compliance procedures for corporate clients dealing with USDT and other digital assets. This applies not only to companies participating in the experimental legal regime (ELR) — all legal entities conducting cryptocurrency transactions have come under scrutiny. According to my data, financial institutions have begun requiring clients to provide detailed explanations of the economic rationale behind stablecoin purchases, as well as confirmation that the counterparty is included in the Bank of Russia's register of digital currency exchange operators. The problem is that this register has not yet been created.
De-risking as a survival strategy
Contrary to assumptions about direct instructions from the Central Bank, the current situation is classic de-risking. Banks are insuring their own risks rather than following formal regulatory directives. Previously, there was an ELR "sandbox" where financial institutions learned to work with crypto assets in a fiat/crypto pairing. Now that cryptocurrency is officially becoming a regulated instrument, banks' compliance departments are trying to minimize potential reputational and legal consequences in advance by requesting data from clients on the origin of funds and the nature of transactions.
The initiative most likely comes from Rosfinmonitoring, which is responsible for law enforcement, rather than from the Central Bank, which is developing the regulatory framework. Banks' actions fall entirely within the scope of Federal Law No. 115-FZ, so they have the legal right to request any clarifications — up to the source of origin of crypto assets. This is not an overreach of authority but standard "know your client" practice in the new realities.
The secret register and uncertainty
The creation of the register of exchange operators is scheduled for autumn of this year. However, its key feature is the maximum confidentiality of information. The logic is clear: ELR participants use cryptocurrencies to circumvent sanctions restrictions, so publicity is inappropriate here. Detailed requirements for the register, limits, and rules for exchanger operations will be established by separate by-laws. It is precisely this gap in the regulatory framework that is causing the current chaos in banking practice.
What is required of businesses right now
Legal entities participating in the ELR will have to disclose the full chain of crypto asset movement: where the coins were acquired, what the source of fiat funds is, and ensure transparency in relations with their own clients. The volume of paperwork for compliance departments of ELR companies will increase significantly. At the same time, companies operating outside the register and without an exchanger license risk facing criminal liability — a bill introducing punishment for illegal cryptocurrency circulation with asset confiscation is being adopted in parallel.
An exception is made only for those using digital currencies under foreign trade contracts. Small players with turnover of up to 3.5 million rubles per month may not be included in the register, but they too are obliged to buy cryptocurrency somewhere — which automatically raises banks' questions about the source of funds.
The new law as a solution to the collision
A separate problem concerns companies forced to use USDT due to closed SWIFT channels. They have to explain the economic rationale of their operations to the bank, which effectively documents the sanctions context. However, from September 1, when the law "On Digital Currency and Digital Rights" comes into force, foreign trade settlements in cryptocurrency will become a fully fledged legal instrument. Banks will be obliged to service such operations provided correctly executed documents are available. The transition period will last until July 1, 2027.
My analysis: the current situation is transitional chaos, which is inevitable when implementing any new regulation. Banks are over-insuring themselves by creating excessive requirements, but once the law takes effect, practice will become unified. The key risk for business is not compliance itself, but the absence of clear criteria for evaluating operations until autumn. I recommend that companies build a transparent documentary base for all crypto operations in advance to minimize friction with banks during this transition period.