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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. The whole problem lies in the "last mile," where money and time disappear after delivery. This is the key pain point that a new Russian legislative initiative is trying to solve.

Last week, on August 4, the President of Russia signed the law "On Digital Currency and Digital Rights." This step came amid global tectonic shifts: the US legislatively banned its own digital dollar, Europe entered final negotiations on the digital euro, the Bank for International Settlements conducted settlements with real money in the Agorá project, and Mastercard closed a deal to acquire a company specializing in stablecoin settlements. All these events answer one question, but the Russian answer is unique: here, the state is building two payment circuits simultaneously, regulating them differently.

The dispute is not about technology, but about control

The real subject of the dispute is not data transmission speed. According to SWIFT statistics, three out of four payments arrive in ten minutes. Time and money are consumed by the "last mile": compliance checks, reconciliation, and crediting at the local bank. The question is whose obligations you hold in your hands at the moment of settlement — the central bank's, a commercial bank's, or a private issuing company's. This determines who is responsible for a lost payment and who benefits from the money while it sits 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 keep clients for. Almost every decision of the past year is designed to keep the balance from leaving the banking system.

Mikhail Kulakov, leading engineer-analyst of the "Blockchain" direction at DiSoft, explains: the question of "whose obligation it is" 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 foreign network to which the bank has only read access. 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 — from July 1, 2027, and part of the requirements for intermediaries — from 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 cases 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: market capitalization above 5 trillion rubles, 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 with a single 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 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 but also self-custody ones are allowed; 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 exemption based on holding period 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, starting September 1, mandatory acceptance of the digital ruble begins — a state retail currency that the US 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 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 US 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 provision.

The combination of public and private circuits is not unique in itself — China, the UAE, and India do the same. The distinctiveness of the Russian model lies in the rigid segmentation by payment purpose, and it is shaped by external circumstances no less than by design.

Kulakov adds: the divergence of trajectories is explained not only by regulatory but also by architectural choices. 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, and 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, by the network, with the bank merely observing.

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 explicitly 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, with the announced March price of 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 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 compared to 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. But compliance checks, sanctions screening, and the resolution of disputed transactions remained outside the scope — and these are precisely what 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. China, from January 1, 2026, 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 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 exceeding 120 million rubles.

For foreign trade participants, the law removes some legal uncertainty within the Russian circuit, but it 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 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 has chosen a unique strategy — not competing for a single global standard, but rigidly separating areas of application. This is pragmatic under current conditions, but it creates the risk of a double regulatory burden on business. The key indicator of success is not the speed of implementation, but whether the state can maintain a balance between control and attractiveness to international partners.