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Transferring $200 abroad costs on average 6.4% of the amount, while the banking channel eats up almost 15%. At the same time, the payment message itself reaches the recipient bank in ten minutes. A paradox? Not at all. The lion's share of time and money is spent not on data transmission, but on the so-called "last mile" — compliance checks, reconciliation, and crediting funds at the local level.

Last week, on August 4, the President of Russia signed the law "On Digital Currency and Digital Rights." This step was a response to global tectonic shifts: 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 the deal to acquire a company specializing in stablecoin settlements. All these events are links in one chain, but the Russian approach stands out with a unique feature: the state is building two payment circuits at once and regulating them differently.

The dispute is not about technology, but about obligations

The bottleneck is not message transmission. According to SWIFT statistics, three out of four payments reach the recipient bank within ten minutes. The real subject of the dispute is the question of 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: they earn on it, they issue loans from it, and they keep clients for its sake. Almost every decision of the past year is designed to ensure the balance does not leave the banking system. Mikhail Kulakov, leading engineer-analyst of the "Blockchain" direction at DiSoft, explains: the question "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 in a third-party network to which the bank has read-only access.

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, with 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 case 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: 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 at 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 makes it permanent. Domestic payments in cryptocurrency are still not allowed. Not only custodial wallets are permitted, but also self-custody ones; when withdrawing over 100 thousand rubles to an external address, a 48-hour delay is provided — it will take effect on September 1, 2027.

Two circuits instead of one

Domestically, starting 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 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 norm: the point is not the transfer fee, but the availability of the channel itself.

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, no 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, with the main work falling on the reconciliation layer between them.

The world, the market, and the practical conclusion

The American framework took shape over a year. The GENIUS Act (July 2025) requires full backing of stablecoins with liquid assets and directly 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 the acquisition of BVNK on August 3. The price announced in March was 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 around a 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 move 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 transactions remained outside the scope — and these are precisely what constitutes the "last mile." Therefore, 80 seconds remains a characteristic of the settlement layer, not of the end-to-end payment.

Country trajectories are diverging. Of the eleven BRICS countries, all are studying digital currencies, nine have reached the pilot stage, but none has launched a full-scale 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, 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 declined 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 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 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 this 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 is avoiding. 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.

My conclusion: Russia is deliberately building a hybrid model where the public circuit ensures control and independence, and the private one provides flexibility for foreign trade. But the key test is not technological but economic: will the digital ruble become attractive to businesses without a forced scenario, or will we witness the Chinese model of "yield on balance," which erodes the very idea of a CBDC.