The Russian crypto market is entering a new phase of institutionalization. The law taking effect on September 1 does not merely introduce targeted bans but establishes a comprehensive system designed to shield retail investors from risks and ensure legal certainty under external pressure. This involves three key areas: advertising, participant registries, and protection of assets from sanctions-related restrictions.
Advertising: What Is Allowed and What Is Not
A key nuance is the distinction between advertising aimed at qualified and non-qualified investors. In open access, it is permitted to mention investments only in those digital currencies available to "non-quals" on exchange trading. Currently, these are Bitcoin (BTC), Ethereum (ETH), and the stablecoin Tether (USDT).
At the same time, advertising of crypto platforms, brokers, and exchangers is not prohibited per se. What is banned is positioning cryptocurrency as a means of payment for goods and services. However, advertising of investments in assets available only to "quals" must be targeted, with confirmation of the investor's status—similar to information requiring age verification.
Registries as a Tool of Trust
The Bank of Russia will take on the maintenance of registries for exchangers, exchanges, management companies, brokers, and depositories. The Federal Tax Service will retain the registry of miners. Such a system will provide consumers with a quick mechanism to verify the legality of a specific professional participant's activities. This is a critically important step: clients will be able to confirm in advance the legitimacy of a platform before entrusting it with their funds.
Sanctions and Protection of Holders' Rights
The new law also grants the government authority to introduce a special regime for the circulation of digital currencies in response to unfriendly actions by foreign states. This is a kind of "emergency mechanism": if another sanctions package attempts to block digital settlement channels, the regulator will be able to flexibly reconfigure the rules. At the same time, the rights of asset holders are guaranteed by law—they will be able to dispose of their assets, transfer them between platforms, and sell them within the Russian jurisdiction.
From my point of view, this is the most balanced approach to regulation of all that we have seen in Russia in recent years. Instead of bans and "gray zones," the legislator offers transparent rules of the game while simultaneously protecting the market from external pressure. However, the success of this model will depend on how quickly and efficiently the operation of the registries is established and how flexibly the regulator can apply the new mechanisms in practice.