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International transfers are always a headache. Sending $200 abroad costs an average of 6.4% in fees, and through a bank, almost 15%. The message itself reaches the recipient bank in ten minutes, but that is just the tip of the iceberg. The main costs and time go into the so-called "last mile"—compliance checks, data reconciliation, and crediting funds at the local level.

This problem is merely a symptom of a deeper debate about who exactly controls settlements. Last week, on August 4, the President of Russia signed the law "On Digital Currency and Digital Rights." Notably, three weeks earlier, the United States legislatively banned its own digital dollar, Europe entered final negotiations on the digital euro, the Bank for International Settlements conducted its first real-money settlements in the Agorá project, and Mastercard closed a deal to acquire a stablecoin company. All these events are responses to the same question, and the Russian approach stands out with a unique solution: building two payment rails at once with different regulations.

The core of the dispute is not technology

The bottleneck is not data transmission. According to SWIFT statistics, three out of four payments reach the recipient bank within ten minutes. What eats up time and money is precisely the "last mile"—checks and reconciliations. The real subject of the dispute is whose obligations you hold in your hands at the moment of settlement: the central bank's, a commercial bank's, a private issuer's, or a payment network's. This determines whom you turn to if a payment goes missing, and who benefits from the funds while they sit in the system.

This balance is the raw material of the banking economy: it is what they earn on, what they issue loans from, and what they keep clients for. Almost every decision of the past year is designed to keep the balance from leaving the banking system. Mikhail Kulakov, lead engineer-analyst for the Blockchain direction at DiSoft, explains: the question of "whose obligation it is" is a question of where the primary record is kept and who has the right to change it. A central bank obligation lives on the regulator's platform, a bank obligation lives in its accounting core, and a token issuer's obligation lives on a third-party network that the bank can only access on a read-only basis. Three answers yield three reconciliation models and three recovery scenarios in the event of a failure.

What the Russian law introduces

The law takes effect on September 1, 2026. Mandatory registration of crypto exchangers in the Bank of Russia registry—from July 1, 2027, with some requirements for intermediaries—from September 2027. A new category of professional participants emerges—digital depositories: they maintain records of clients' crypto assets, host primary and backup IT infrastructure in Russia, and compensate for losses in the event of unauthorized debits. Crypto exchangers with own funds of at least 15 million rubles are legalized.

The criteria for admitting assets to trading are enshrined in the law itself: market capitalization above 5 trillion rubles, average daily turnover above 1 trillion, and a trading history of at least five years, all averaged over two years. Bitcoin and ether currently meet these criteria. For non-qualified investors, a limit of 300 thousand rubles per year per intermediary and mandatory testing are established.

The provision that will affect practice sooner than others is settlements under foreign trade contracts. It has been in effect since September 2024 in an experimental mode by the Bank of Russia, and the new law makes it permanent. Domestic payments in cryptocurrency remain prohibited. Not only custodial wallets but also self-custodial ones are permitted; withdrawals exceeding 100 thousand rubles to an external address are subject to a 48-hour delay—this will take effect on September 1, 2027.

The Central Bank's list itself does not prohibit holding assets outside it: the criteria apply to public offerings through Russian intermediaries, not to ownership rights, and digital currency is recognized as property with judicial protection. Foreign and non-custodial wallets are not prohibited, and the owner is recognized as the holder of the access key. The obligation to declare the mere fact of ownership is not directly established—except for civil servants. Two or more transactions per month exceeding 3.5 million rubles are considered by the law as a sign of organized activity requiring intermediary status.

Tax arises upon sale, not upon holding: 13% on income up to 2.4 million rubles and 15% above that, with a 3-NDFL declaration due by April 30. The holding-period exemption applicable to certain types of property does not apply to digital currency. From July 1, 2027, banks are required to refuse transfers to unlicensed crypto services—the channel for funding foreign platforms through Russian banks closes.

Two rails instead of one

Domestically, from September 1, mandatory acceptance of the digital ruble begins—a state retail currency that the United States has rejected until the end of 2030 and that Europe is only designing so far. Externally, the circulation of private global assets is legalized. Both instruments are used simultaneously but separated by purpose: domestically—only the public rail, externally—only the private one.

The logic of separation is simple if you look at obligations. Domestically, the balance remains with the Bank of Russia: this provides traceability of settlements and independence from external infrastructure—and at the same time raises the same privacy question that led the United States to abandon the retail model. Externally, an asset is used that no party to the transaction issues—which is why it works where correspondent channels have become difficult to navigate due to external restrictions in recent years. The sanctions context is not named in the law, but it is the most obvious explanation for the foreign trade provision: it is not about the transfer fee but about the availability of the channel itself.

The combination of public and private rails is not unique in itself—China, the UAE, and India do the same. The distinctiveness of the Russian model lies in the rigid segmentation by payment purpose, and it is shaped by external circumstances no less than by design. The divergence in trajectories is explained not only by regulatory but also by architectural choices, Kulakov adds. Retail central bank projects in BRICS are built on centralized platforms where the distributed ledger is used selectively. Stablecoins live in the opposite paradigm—public networks, an open ledger, and no single operator. Therefore, two rails are not two interfaces but two different data models: in one, the record is created by the platform operator; in the other, it is created by the network, and the bank only observes, with the main work falling on the reconciliation layer between them.

The world, the market, and the practical takeaway

The American framework took shape over a year. The GENIUS Act (July 2025) requires full backing of stablecoins with liquid assets and explicitly prohibits paying holders income on the token. And on July 11, 2026, the ban on a retail central bank digital currency became law: until the end of 2030, the Fed is not authorized to issue a CBDC. Europe chose the opposite instrument: the digital euro is being designed as a public alternative with zero yield and a holding limit; the regulation has not been adopted, a pilot is planned for the second half of 2027, and the first issuance for 2029.

Mastercard closed its acquisition of BVNK on August 3, with the announced March price of up to $1.8 billion, including about $300 million in contingent payments. The asset's value is largely regulatory: BVNK obtained a MiCA license in Malta in February 2026, valid across the entire EU. In July, Visa launched a stablecoin issuance platform for banks. Card networks are embedding new instruments into the settlement layer while retaining the client and the rules: they do not need the balance; they earn on the flow. The share of stablecoins in cross-border retail payments in 2025 was 0.31%.

The only one to report real-money settlements is the Bank for International Settlements project. On July 30, results were published: about thirty participants, including five central banks, 30 transactions in six currencies totaling roughly one million dollars, with an average settlement time of 80 seconds versus several business days in correspondent practice. At the same time, the platform operated autonomously, without connection to existing systems and without real compliance procedures. The engineering value of Agorá is that there is no need to migrate accounting anywhere: the tokenized deposit remains the same bank's obligation, the ledger handles atomicity and synchronization, and data migration is not required, Kulakov explains. But compliance checks, sanctions screening, and the resolution of disputed transactions remained outside the scope—and these are precisely what constitute the "last mile."

Country trajectories diverge. Of the eleven BRICS countries, all are studying digital currencies, nine have reached the pilot stage, but none has fully launched a system. China, from January 1, 2026, reclassified the digital yuan in commercial bank accounts as a deposit obligation—it now accrues interest and is covered by deposit insurance. India is moving in the opposite direction: the volume of digital rupee in circulation declined for the first time by 24% in fiscal year 2025/26. Brazil, in November 2025, shut down the Drex platform, admitting that the technology failed to ensure privacy and security.

The digital ruble looks modest—as of July 1, over 25 million digital rubles were in circulation, about $320 thousand for the entire country—but in two months, acceptance becomes mandatory for companies with revenue above 120 million rubles. For foreign trade participants, the law removes some legal uncertainty within the Russian framework, but it does not regulate the external side of the transaction: the willingness of a foreign counterparty to accept payment is determined by its own compliance and its assessment of sanctions risk.

My takeaway: Russia is building not just two rails but two different philosophies of money—public domestically and private externally. The question for the next year and a half is not whether the rails of different countries will connect, but whether Russia will repeat China's maneuver—accrue income or otherwise return the balance to banks. The answer will be visible in the dynamics of the deposit base by the end of 2027.