Double circuit: how the new digital currency law divides Russia's payment system
Transferring $200 abroad costs on average 6.4% of the amount, while through a bank it costs almost 15%. At the same time, the payment message itself reaches the recipient bank in ten minutes. This paradox is just the tip of the iceberg in the global debate about the future of payments.
The key problem lies not in data transmission speed, but in the so-called "last mile"—the complex of checks, reconciliations, and crediting at the local bank. This is where the main time and financial costs are concentrated. Over one month, five different approaches attempted to close this gap, and the Russian approach stands out particularly vividly against this backdrop.
New Architecture: Two Circuits Instead of One
On August 4, the President of Russia signed the law "On Digital Currency and Digital Rights." This event took place against the backdrop of landmark global decisions: the U.S. legally banned its own digital dollar until 2030, Europe entered final negotiations on the digital euro, the Bank for International Settlements conducted the first real-money settlements in the Agorá project, and Mastercard closed a deal to acquire a company specializing in stablecoin settlements.
All five approaches answer one question: who bears responsibility for funds at the moment of settlement—the central bank, a commercial bank, or a private issuer? The Russian answer is unique: the state is building two payment circuits simultaneously, regulating them differently.
What Changes in Practice
The law takes effect on September 1, 2026. Mandatory registration of crypto exchanges in the Bank of Russia registry will begin on July 1, 2027, and part of the requirements for intermediaries—from September of that same year. A new category of professional participants emerges—digital depositories, which will maintain records of clients' crypto assets, store key IT infrastructure in Russia, and compensate for damages in case of unauthorized debits.
Crypto exchanges with own funds of at least 15 million rubles are legalized. The admission of assets to trading is enshrined in the law: market capitalization above 5 trillion rubles, average daily turnover exceeding 1 trillion, and a trading history of at least five years. Today, bitcoin and ether fall under these criteria. For non-qualified investors, a limit of 300 thousand rubles per year with one intermediary is set, along with mandatory testing.
Domestic payments in cryptocurrency remain prohibited. Not only custodial but also self-custody wallets are allowed; when withdrawing over 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 concern public offerings through Russian intermediaries, not ownership rights. Foreign and non-custodial wallets are not prohibited—the owner is recognized as the one holding the access key.
Tax arises upon sale, not 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 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 is closing.
Public and Private: Separation by Purpose
Domestically, starting September 1, mandatory acceptance of the digital ruble—the state's retail currency—begins. 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 separation is simple. Domestically, the balance remains with the Bank of Russia: this provides traceability of settlements and independence from external infrastructure, but simultaneously raises the question of privacy, the very reason the U.S. abandoned the retail model. Externally, an asset is used that no transaction participant issues—which is why it works where correspondent channels have become difficult to navigate due to external restrictions in recent years.
The pairing of public and private circuits is not unique—China, the UAE, and India do the same. The distinctiveness of the Russian model lies in the rigid segmentation by payment purpose, shaped by external circumstances no less than by design.
Global Context and Practical Conclusion
The American framework took a year to develop. The GENIUS Act (July 2025) requires full backing of stablecoins with liquid assets and directly prohibits paying holders income on tokens. 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 designed as a public alternative with zero yield and a holding limit, with a pilot planned for the second half of 2027 and the first issuance for 2029.
Mastercard closed the acquisition of BVNK on August 3 for $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.
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 held 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 digital rupee in circulation fell for the first time by 24% in the 2025/26 fiscal year. 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 exceeding 120 million rubles.
Mandatory acceptance of the digital ruble creates a forced flow from bank balances into a Central Bank liability—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 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.
My analysis: the division into two circuits is not a technical solution but a strategic choice. The public circuit ensures control and independence, the private one—flexibility in circumventing sanctions restrictions. However, the viability of the model depends on whether the regulator can maintain a balance between forced implementation and market appeal. If the digital ruble remains merely a control tool rather than a convenient means of payment, it risks repeating Drex's fate—being rejected by the market.