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International transfers are a real headache for businesses and individuals. Sending $200 abroad today costs on average 6.4% of the amount, and through a bank — almost 15%. At the same time, the payment message itself reaches the recipient bank in ten minutes. All the remaining time and money go to what happens after delivery: compliance checks, reconciliations, and crediting at the local bank. Over the course of one month, five different approaches attempted to close this gap.

Last week, on August 4, the President of Russia signed the law "On Digital Currency and Digital Rights." Three weeks earlier, the U.S. legislatively banned its own digital dollar, Europe sat down for 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 acquisition of a company specializing in stablecoin settlements. All five are answering one question, and the Russian answer differs in one respect: only here is the state building two payment rails simultaneously and regulating them differently.

The dispute is not about technology

The bottleneck is not message transmission: according to SWIFT statistics, three out of four payments reach the recipient bank within ten minutes. Time and money are consumed by the "last mile" — compliance checks, reconciliation, and crediting at the local bank. The real subject of the dispute becomes visible if you ask whose obligation you hold in your hands at the moment of settlement — the central bank's, a commercial bank's, a private issuer's, or a payment network's. This determines whom to turn to if a payment goes missing, and who benefits from the funds while they sit 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, lead engineer-analyst in the "Blockchain" division 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. A central bank's obligation lives on the regulator's platform, a bank's own obligation lives in its accounting core, and a token issuer's obligation lives on a third-party 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, and the "last mile" is largely the time spent aligning these records with each other, not a delay in data transmission.

What the Russian law introduces

Ravil Akhtyamov reminded that the law takes effect on September 1, 2026, mandatory registration of crypto exchanges 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, host primary and backup IT infrastructure in Russia, and compensate damages in the event of unauthorized debits. Crypto exchanges 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, all averaged over two years. Bitcoin and ether currently fall under these criteria. For non-qualified investors, a limit of 300 thousand rubles per year per 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 at 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 permitted; 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, and 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 state and municipal employees. 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 holding-period exemption applicable to certain types of property does not apply to digital currency, according to Ministry of Finance clarifications. From July 1, 2027, banks are required to refuse transfers to unlicensed crypto services — the channel for funding foreign platforms through a Russian bank is closing.

Two rails instead of one

Akhtyamov emphasized: domestically, starting September 1, mandatory acceptance of the digital ruble begins — a state retail currency that the U.S. 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 rail, 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 — while simultaneously raising the same privacy question that led the U.S. to abandon the retail model. Externally, an asset issued by none of the transaction participants is used — 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 issue is not the transfer fee, but the availability of the channel itself.

The combination of public and private rails 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. The divergence of 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 record book, no single operator. Therefore, two rails are not two interfaces but two different data models: in one, the record is created by the platform operator; in the other, it is created by the network, and the bank only observes, with the main work falling on the reconciliation layer between them.

The world, the market, and the practical takeaway

The American construct 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. According to ECB data, in 2022 international card schemes accounted for 61% of eurozone card payments, and thirteen countries depend on them entirely. 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 at up to $1.8 billion, including about $300 million in earn-out 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. Results were published on July 30: about thirty participants, including five central banks, 30 transactions in six currencies totaling roughly one million dollars, with an average settlement time of 80 seconds versus several business days in correspondent practice. However, 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 same bank's obligation, the ledger handles atomicity and synchronization, and data migration is not required, Kulakov explains. But compliance checks, sanctions screening, and dispute resolution remained outside the scope — and these are precisely what constitutes the "last mile" — so 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 — 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 digital rupee in circulation declined for the first time by 24% in FY 2025/26, 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 rail, 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. Bitcoin and ether admitted to trading are volatile, which is an independent risk for contracts 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 rails of different countries will interconnect, but whether Russia will repeat the Chinese maneuver — accrue yield 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 building a unique hybrid model where a public rail for domestic settlements and a private one for foreign trade coexist but do not intersect. This is a pragmatic response to sanctions restrictions, but it creates a structural risk: a forced outflow of liquidity from the banking system into the digital ruble could hit lending. The key indicator is deposit behavior after September 1, 2026. If the Central Bank begins to accrue yield on the digital ruble, we will see a repeat of the Chinese scenario, and then the difference between the "public" and "private" rails will become even more blurred.