The Era of Controlled Legalization: How the Central Bank of the Russian Federation Revised Its Approach to Cryptocurrencies and What It Means for Business

The Bank of Russia has submitted a concept for regulating the cryptocurrency market to the government, marking a historic shift in state policy. Moving from the idea of a total ban, the regulator has adopted a strategy of controlled legalization, integrating digital assets into the existing financial system. This program document is not a final law, but a roadmap that will set the vector for all future regulation in the coming years.

In 2021–2022, the Bank of Russia insisted on a complete ban on cryptocurrencies, viewing them as a threat to stability and a channel for capital flight. However, geopolitical changes, the disruption of traditional payment chains, and the real needs of businesses for cross-border transaction tools tipped the scales. The 2025 concept is a pragmatic recognition of reality: crypto-assets have become a working tool, and they cannot be ignored, but they can and should be regulated.

The concept is built on several fundamental pillars that separate the "permissible" from the "prohibited."

1.Cryptocurrency is an Asset, Not Money. Digital assets are recognized as foreign exchange valuables. They can be bought, sold, and stored, but their use as a means of payment for goods and services within Russia remains prohibited. The only legal tender is the ruble.

2.Investor Protection Through Segmentation. The familiar model of investor categorization will be applied to the crypto market:

• Unqualified investors will have access only to the most liquid assets (e.g., BTC, ETH) with an annual limit of 300,000 rubles and mandatory testing.
• Qualified investors will be able to work with any crypto-assets (except anonymous ones like Monero) without limits, but with increased responsibility.

3.Infrastructure Based on Existing Institutions. A separate "crypto-system" will not be created for integration. Trading digital assets will be possible through existing exchanges, brokers, and trust managers under their current licenses. New requirements will only affect crypto-depositories and exchangers.

4.Transparency of Cross-Border Operations. The use of cryptocurrencies for international settlements is recognized. Residents will be allowed to purchase crypto-assets abroad, but with mandatory notification of tax authorities. This equates cryptocurrency with foreign exchange valuables in terms of control.

5.Development of Digital Financial Assets (DFAs). A significant step will be the permission to issue and circulate DFAs in open blockchain networks, which will expand the pool of potential investors and allow Russian companies to raise capital internationally.

For businesses already using or considering crypto-assets, the concept removes the main uncertainty — the fear of a complete ban. It is now clear that a legal path exists. However, it will require adaptation:

1. For Legal Entities and Entrepreneurs: Cryptocurrencies are transitioning from a grey area into the field of regulated assets. This entails the need for clear tax accounting, compliance with anti-money laundering (AML/CFT) requirements, and the use of only licensed intermediaries for operations.
2. For Financial Institutions: Banks, brokers, and exchanges will gain a new segment for service development, but within strict regulatory frameworks. They will have to build compliance systems, develop products for different investor categories, and ensure transaction security.
3. For Private and Institutional Investors: Legal certainty and protection when working with digital assets through legal channels are emerging. However, it is important to prepare for investment volume restrictions (for unqualified individuals) and mandatory verification procedures.

The regulator provides the market with a significant adaptation period:

• Until July 1, 2026 — formation and adoption of the necessary legislative framework.
• From July 1, 2027 — introduction of liability for illegal activities of intermediaries.

This means that companies have nearly two years to assess risks, prepare internal processes, establish cooperation with licensed operators, and develop a strategy for working with digital assets.

The transition from a legal vacuum to a regulated market is a complex process associated with legal, tax, and operational risks. Acsour offers comprehensive support to businesses at all stages of integration into the new regulatory environment:

• Legal Consulting: analysis of business models for compliance with future norms, assistance in preparing internal policies and documents for working with crypto-assets, consultations on cross-border operations.
• Tax Planning and Accounting: development of a tax accounting scheme for operations with digital assets, consultations on personal income tax (PIT), VAT, and corporate profit tax, assistance in preparing reports.
• Compliance and AML/CFT: risk assessment, development and implementation of internal control rules, preparation for interaction with regulators.
• Deal Structuring: assistance in choosing optimal legal structures and licensed intermediaries for safe market entry.

The Central Bank's new concept opens a period of controlled legalization of digital assets. Submit a request for a consultation with Acsour experts in digital assets and financial regulation.