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Transferring $200 abroad via cryptocurrency costs on average 6.4% of the amount, while a classic bank transfer eats up almost 15%. Moreover, the payment message itself reaches the recipient bank within ten minutes. Digital economist Ravil Akhtyamov cites these figures as a starting point for understanding the new regulation.

All the remaining time and money are spent on what happens after the message is delivered. Over one month, five different approaches were tried to close this gap. Only Russia approached the issue fundamentally.

The essence of the dispute is not in the technology

The bottleneck is not data transmission. According to SWIFT statistics, three out of four payments reach the recipient bank within ten minutes. Time and money are consumed by the "last mile" — compliance checks, reconciliation, and crediting at the local bank. The real subject of the dispute is whose obligation you hold in your hands at the moment of settlement: the central bank's, the commercial bank's, the private issuer company's, or the payment network's.

This determines who you turn to if a payment goes missing, and who uses the money while it sits 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, leading engineer-analyst of the "Blockchain" direction at the company "Diasoft," explains: the question "whose obligation is this" is a question of where the primary record is maintained and who has the right to change it. The central bank's obligation lives on the regulator's platform, the bank's own obligation lives in its accounting core, and the token issuer's obligation lives in a foreign network to which the bank has read-only access. Three answers yield three reconciliation models and three recovery scenarios in the event of a failure.

What the Russian law introduces

The law comes into force on September 1, 2026, mandatory registration of crypto exchanges in the Bank of Russia registry — from July 1, 2027, and part of the requirements for intermediaries — from September 2027. A new category of professional participants appears — digital depositories: they maintain records of clients' crypto assets, hold primary and backup IT infrastructure in Russia, and compensate for damages in the event of unauthorized debits. Crypto exchanges with own funds of at least 15 million rubles are legalized.

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

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

The Central Bank's list itself does not prohibit owning assets outside it: the criteria apply to public offerings through Russian intermediaries, not to property rights. Digital currency is recognized as property with judicial protection. Foreign and non-custodial wallets are not prohibited; the owner is recognized as the one holding the access key. The obligation to declare the very 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 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 obliged to refuse transfers to unlicensed crypto services — the channel for funding foreign platforms through a Russian bank closes.

Two circuits instead of one

Domestically, from September 1, mandatory acceptance of the digital ruble begins — the state retail currency that the United States has legislatively 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 circuit, externally — only the private one.

The logic of the 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 simultaneously 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 traverse due to external restrictions of recent years. The sanctions context is not named in the law, but it is the most obvious explanation for the foreign trade norm: it is not about the transfer fee but about the availability of the channel itself.

The combination of public and private circuits is not unique in itself — China, the UAE, and India do the same. The peculiarity 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 projects of central banks 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 the absence of a single operator. Therefore, the two circuits are not two interfaces but two different data models: in one, the operator of the platform creates the record; in the other, the network creates it, and the bank only observes.

The world, the market, and the practical conclusion

The American construct took shape over a year. The GENIUS Act (July 2025) requires full backing of stablecoins with liquid assets and directly prohibits accruing income to holders for 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 entitled to issue a CBDC. Europe chose the opposite instrument.

According to ECB data, in 2022, international card schemes accounted for 61% of eurozone card payments, and thirteen countries depend on them entirely. That is why 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 the 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 license under the MiCA regulation 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 settlements with real money 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 around 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 obligation of the same bank, the ledger takes on atomicity and synchronization, and data migration is not required. But compliance checks, sanctions screening, and the resolution of disputed operations 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. Since January 1, 2026, China has reclassified the digital yuan in commercial bank accounts as a deposit obligation — interest accrues on it and deposit insurance applies. India is moving in the opposite direction: the volume of the digital rupee in circulation shrank for the first time by 24% in the 2025/26 fiscal year, and Brazil in November 2025 shut down the Drex platform, admitting that the technology did not 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 exceeding 120 million rubles. For foreign trade participants, the law removes part of the legal uncertainty within the Russian circuit but 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 assessment of sanctions risk. Bitcoin and ether admitted to trading are volatile, and that is an independent risk for a contract with deferred payment.

My conclusion: mandatory acceptance of the digital ruble creates a forced flow from bank balances into a Central Bank obligation — exactly what everyone else avoids. The question of the next year and a half is not whether the circuits of different countries will align, but whether Russia will repeat the Chinese 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.