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The average fee for transferring $200 abroad is about 6.4% of the amount, while a classic bank transfer will cost almost 15%. The payment order itself reaches the recipient bank in ten minutes. I cite these figures not by chance: they illustrate the key problem that the new Russian law on digital currency is trying to solve.

The vast majority of time and money is spent not on transmitting the message, but on the so-called "last mile" — compliance checks, data reconciliation, and crediting funds to an account at a local bank. According to SWIFT statistics, three out of four payments reach the recipient in those same ten minutes. All the remaining delay is manual work after delivery.

The essence of the dispute is not in the technology

The real subject of the discussion is the question of the obligation: whose obligation exactly are you holding in your hands at the moment of settlement? The central bank's, a commercial bank's, a private issuer company's, or a payment network's? This determines who you go to with a claim if a payment is "lost," and who uses the money while it is 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 retain clients for. Virtually every regulatory decision over the past year has been structured to keep this balance from leaving the banking system.

Mikhail Kulakov, leading engineer-analyst of the "Blockchain" direction at DiSoft, explains: the question of "whose obligation is this" is a question of where the primary record is kept 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 on a third-party 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. The "last mile" is largely the time spent reconciling these records with each other, not a data transmission delay.

What the Russian law introduces

The law comes into force on September 1, 2026. Mandatory registration of crypto exchangers 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, keep primary and backup IT infrastructure in Russia, and compensate for damages in the event of unauthorized write-offs. 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: 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 fall under these criteria today. For non-qualified investors, a limit of 300 thousand rubles per year with one intermediary and mandatory testing are established.

The provision 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 makes it permanent. Domestic payments in cryptocurrency are still not allowed. 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 on 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 is closing.

Two circuits instead of one

Domestically, from September 1, mandatory acceptance of the digital ruble begins — a 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 the 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 that none of the transaction participants issues is used — which is why it works where correspondent channels have become difficult to traverse 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: the point is not the transfer fee, but the availability of the channel itself.

The pairing 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 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 record book, no single operator. Therefore, the two circuits 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 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 authorized 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 its acquisition of BVNK on August 3; the price announced in March is up to $1.8 billion, including about $300 million in contingent payments. The asset's value is largely regulatory: BVNK received 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 for themselves: 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. However, 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, Kulakov explains. But compliance checks, sanctions screening, and the resolution of disputed operations remained outside the scope, and it is precisely these that constitute the "last mile" — therefore, 80 seconds remain a characteristic of the settlement layer, not of an end-to-end payment.

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 reclassified the digital yuan in commercial bank accounts as a deposit obligation — interest accrues on it and deposit insurance applies, meaning Beijing decided to return the balance to banks through yield. 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 above 120 million rubles. For foreign trade participants, the law removes part of the legal uncertainty within the Russian circuit, but it does not regulate the external side of the transaction: the foreign counterparty's willingness 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.

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 for 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.

My conclusion: Russia is deliberately building a hybrid model where the public circuit ensures control over domestic money circulation, while the private one addresses the task of foreign economic activity under sanctions restrictions. The key risk is not technological but behavioral: if the digital ruble does not become convenient and profitable for businesses, mandatory acceptance will only give rise to new circumvention schemes, and then the entire two-circuit construct will prove to be nothing more than a formal facade.