Fines up to a million: how Russia will punish illegal crypto advertising
The Russian crypto advertising market is entering a new era of strict regulation. Starting September 2024, rules come into effect that radically change the game for companies promoting digital assets. Now, violations carry fines ranging from 100,000 to 1 million rubles, and oversight functions are distributed among three key agencies: the FAS, Roskomnadzor, and the Bank of Russia. I have broken down the step-by-step mechanism for identifying and punishing violators so you understand how to protect your business.
Who punishes and for what
The basic advertising fine for legal entities under Part 1 of Article 14.3 of the Administrative Code ranges from 100 to 500 thousand rubles. This is the classic liability for improper advertising. However, for spam mailings without recipient consent, a separate, stricter offense applies—sanctions reach up to 1 million rubles. If the violation concerns ERID labeling and the transfer of internet advertising data, Roskomnadzor will step in, and fines for companies will also amount to up to 500 thousand rubles. In cases where the violator is a regulated exchanger or digital depository, oversight from the Central Bank is added as well.
The mechanism is triggered simply: a complaint can be filed by a user, a competitor, or any interested party. The FAS can also initiate an inspection on its own upon identifying signs of a violation. For complaints about internet advertising, the antimonopoly authority recommends recording a full screenshot of the page, the website address, and the date. The agency then evaluates the materials, opens a case on violation of advertising legislation, and the FAS commission issues a decision. If the advertising is deemed improper, an order to cease the violation is issued.
Important: the FAS does not need to go to court to impose a fine. The company can appeal the decision, order, and ruling only after they are issued. This sequence shows that most often the signal comes from external sources or from the regulator's own monitoring. The key evidence is a recorded advertising material with specific wording.
A new philosophy of regulation
Starting in September, the very philosophy of regulation changes. In 2024, the state first banned advertising of a market that was effectively unregulated. Now, this market has begun to be institutionalized: legal organizers of circulation have emerged, and with them, the opportunity to advertise their activities. The formula is simple: cryptocurrency as such cannot be advertised, but crypto infrastructure and regulated services can. This is one of the most practical changes of the new regulation.
For the first time, the market gets the opportunity to legally tell the client: "we provide exchange services" or "we carry out digital accounting." However, the transition period adds uncertainty. The new rules are already in effect, but the Central Bank registry, which grants the right to use them in full, is only being formed. Until July 1, 2027, many existing exchangers remain outside the new advertising regime.
In the coming months, market participants will have to balance between the old operating model and new requirements. My recommendation: caution in wording and completeness of mandatory disclosures are your main protection against regulator claims. The transition period is not a time for experiments, but a time for building compliance procedures that will become the foundation for legal growth in the new reality.