The Central Bank's limit of 300,000 rubles: how an investor can legally bypass the restriction through multi-intermediation
The annual limit of 300,000 rubles on cryptocurrency purchases set by the Central Bank applies to each counterparty separately, rather than being summed across all of an investor's transactions. This opens up a legal opportunity for large depositors: distributing deals among several banks, brokers, and exchangers allows the threshold to be bypassed without violating the regulator's formal requirements.
For most non-qualified investors, the set amount is quite sufficient—it covers typical savings volumes. However, those who operate with capital above this threshold can take advantage of a gap in regulation: the restriction does not extend to the number of intermediaries through which purchases are made. In essence, the regulator does not prohibit splitting transactions, which creates a legal mechanism for increasing the volume of investments.
What the limit protects and why it benefits intermediaries
On one hand, this format formally shields inexperienced market participants from excessive volatility—this is what the regulator declares as its main goal. On the other hand, it provides intermediaries with a time lag to adjust infrastructure and train specialists working with cryptocurrencies. There is also an indirect effect: client funds are distributed across different depositories, which reduces the risks of sanctions application. In the case of BTC and ETH, freezing at the blockchain level is technically unfeasible, but risks of coin marking remain.
A separate issue is the lack of cross-platform data exchange. A unified system that would consolidate a client's operations across different intermediaries currently does not exist. Information is fully confidential and is transmitted to the regulator only in cases of suspicious activity. This opens room for abuse: a client can present the same documents on the origin of funds to different intermediaries, and the intermediary itself is responsible for verifying them. Monitoring the limit within a single intermediary also falls on its shoulders—companies track compliance with the threshold through internal reporting, which makes the process fairly transparent for the regulator.
What cross-platform accounting will change
Accounting for client activity by TIN in the future will give the regulator far more transparency. Likely, this will be followed by the introduction of a cumulative limit across all platforms at once. For now, no official system for such control in a desk-based manner exists. Earlier, economist Mikhail Bryukhanov explained that distributing transactions among different licensed intermediaries remains a legal way to buy cryptocurrency for more than 300,000 rubles per year, since the restriction mechanism itself raises no objections to such operations.
For everyday expenses, this amount is quite sufficient, but it will not cover a car or foreign real estate. Qualified investors are not affected by the new rules: the restrictions do not apply to those who meet educational and professional requirements or have passed special testing.
My expert view: the current design of the limit is a temporary measure that will inevitably evolve toward tightening. As cross-platform accounting by TIN is implemented, the possibility of multi-intermediation will disappear, so large investors should use the current window of opportunity, but with an eye on upcoming changes in the regulatory environment.