Cryptoreform in Russia: two payment circuits instead of one — analysis of the new law
Transferring $200 abroad costs on average 6.4% of the amount, while through a bank it is almost 15%. At the same time, the payment message itself reaches the recipient bank in ten minutes. All the remaining delay and costs are the "last mile": compliance checks, reconciliations, and crediting at the local bank. This is where the essence of the global dispute over the future of digital money lies, not in data transmission speed.
The essence of the dispute: not technology, but obligations
The question is not how fast a transaction moves, but whose obligation you hold in your hands at the moment of settlement. The answer depends on the architecture: a central bank, a commercial bank, or a private issuer. This determines who you turn to if a payment goes missing, and who benefits from the funds while they sit in the system. The balance is the raw material of the banking economy: it is what profits are made from, and it is what loans are issued from.
Mikhail Kulakov, lead engineer-analyst in the Blockchain division 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. A central bank's obligation lives on the regulator's platform, a bank's obligation lives in its accounting core, and a token issuer's obligation lives in a third-party network that the bank only has read access to. 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 begins on July 1, 2027, and part of the requirements for intermediaries begins in September 2027. A new category of professional participants emerges—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 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: a market capitalization above 5 trillion rubles, an average daily turnover above 1 trillion, and a trading history of at least five years. Bitcoin and ether currently meet these criteria. For non-qualified investors, a limit of 300 thousand rubles per year per intermediary is set, along with mandatory testing.
The provision that will affect practice earlier 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 are allowed, but also self-custodial ones; withdrawals exceeding 100 thousand rubles to an external address are subject to a 48-hour delay—this will take effect on September 1, 2027.
Two circuits instead of one
Domestically, starting 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 still only designing. Externally, the circulation of private global assets is legalized. Both instruments are used simultaneously but are separated by purpose: domestically, only the public circuit; externally, only the private one.
The logic of the separation is simple when viewed through obligations. Domestically, the balance remains with the Bank of Russia: this ensures traceability of settlements and independence from external infrastructure. 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.
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 strict segmentation by payment purpose, and this is shaped by external circumstances no less than by design.
Global context and 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 has chosen 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. This is why the digital euro is being designed as a public alternative with zero yield and a holding limit. Mastercard closed its acquisition of BVNK on August 3, with the announced price at 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.
Countries' 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—it now accrues interest and is covered by deposit insurance. India is moving in the opposite direction: the volume of the digital rupee in circulation shrank by 24% for the first time in the 2025/26 fiscal year. Brazil shut down the Drex platform in November 2025, 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.
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 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 conclusion: Russia is deliberately building a hybrid model where the public circuit ensures control domestically and the private one provides flexibility externally. But the key risk is not technical but behavioral: if the digital ruble remains an instrument without yield, businesses will minimize balances, and the regulator will have to either tighten requirements or seek new incentives. This deserves closer attention than implementation timelines.