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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. I cite these figures not for rhetorical effect, but to emphasize: the bottleneck of the global financial system has long shifted from the realm of technology to the realm of trust and accounting.

The essence of the dispute is not technology

The problem is not data transmission speed. According to SWIFT statistics, three out of four payments reach the recipient bank in the same ten minutes. The main costs and delays arise at the "last mile"—the stage of compliance checks, reconciliations, and crediting at the local bank. It is here that it is decided whose obligations you hold in your hands at the moment of settlement: the central bank's, the commercial bank's, or a private issuer company's. This balance is the raw material of the banking economy, from which profits are made, loans are issued, and for which clients are retained.

Mikhail Kulakov, leading engineer-analyst of the Blockchain division at DiASoft, rightly notes: 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, the bank's own obligation lives in its accounting core, and a token issuer's obligation lives on a foreign network to which the bank has read-only access. Three answers yield three reconciliation models and three recovery scenarios in the event of a failure.

What the Russian law introduces

The law "On Digital Currency and Digital Rights" 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 emerges—digital depositories: they maintain records of clients' crypto assets, hold primary and backup IT infrastructure in Russia, and compensate for damages in cases of unauthorized write-offs.

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 currently meet these criteria. For non-qualified investors, a limit of 300 thousand rubles per year with one intermediary and mandatory testing are established.

The provision on settlements under foreign trade contracts, which had been in effect since September 2024 in an experimental mode, is now converted to permanent status. Domestic cryptocurrency payments remain prohibited. Not only custodial wallets but also self-custody ones are permitted; for withdrawals exceeding 100 thousand rubles to an external address, a 48-hour delay is provided—it will take effect from 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, and 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 as 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 Russian banks closes.

Two circuits instead of one

Domestically, from 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 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 simultaneously 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. The sanctions context is not named in the law, but it is the most obvious explanation for the foreign trade provision: the issue is not the transfer fee, but the availability of the channel itself.

The pairing of public and private circuits is not unique—China, the UAE, and India do the same. The peculiarity of the Russian model lies in the strict 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 platform operator creates the record; in the other, the network creates it, and the bank merely observes.

The world, the market, and the practical conclusion

The American structure took shape within a year. 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. According to ECB data, in 2022 international card schemes accounted for 61% of eurozone card payments, and thirteen countries are fully dependent on them. That is why 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. Results were published on July 30: about thirty participants, including five central banks, 30 transactions in six currencies totaling approximately one 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 migrate accounting anywhere: the tokenized deposit remains the obligation of the same bank, the ledger handles atomicity and synchronization, and no data migration is 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."

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. 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 has 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. Brazil shut down the Drex platform in November 2025, acknowledging 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 above 120 million rubles. For foreign trade participants, the law removes part of the legal uncertainty within the Russian circuit, but it does not regulate the external side of the transaction: the foreign counterparty's willingness to accept payment is determined by its own compliance and assessment of sanctions risk.

The bitcoin and ether admitted to trading are volatile, which 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 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 two-circuit model where the public digital ruble ensures control domestically, and private crypto assets provide flexibility externally. But the key risk is not technological but economic: if the balance begins to massively leak from the banking system into a Central Bank obligation, the regulator will have to either introduce yield or reinstate limits. The Chinese scenario is just one of the possible answers to this challenge.